Hartland Assoc. v. Commissioner
United States Tax Court
Held, the cancellation of interest indebtedness by the shareholder-creditor of Hartland Corp. did not result in the receipt of income by the corporation notwithstanding the deduction of such interest as it accrued in prior years. Such cancellation constituted, rather, a capital contribution to the corporation.
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Held, the cancellation of interest indebtedness by the shareholder-creditor of Hartland Corp. did not result in the receipt of income by the corporation notwithstanding the deduction of such interest as it accrued in prior years. Such cancellation constituted, rather, a capital contribution to the corporation. Held, further, Hartland Corp. must be denied a deduction for accrued rentals payable in favor of its controlling shareholder which remained unpaid as of the close of the 2 1/2-month period following the taxable year. A document evidencing the rental indebtedness issued by the…
1Opinion of the Court
Hartland Associates (a Partnership) Transferee of the Assets of Hartland Hospital (a Dissolved Corporation), Petitioner v. Commissioner of Internal Revenue, Respondent
Hartland Assoc. v. Commissioner
Docket Nos. 4713-67, 4714-67
United States Tax Court
54 T.C. 1580; 1970 U.S. Tax Ct. LEXIS 85;
August 5, 1970, Filed
Decisions will be entered under Rule 50.
Held, the cancellation of interest indebtedness by the shareholder-creditor of Hartland Corp. did not result in the receipt of income by the corporation notwithstanding the deduction of such interest as it accrued in prior years. Such cancellation…
2Cases cited30 opinions
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- Marcello v. CommissionerUnited States Tax Court · 1964
- Bedell v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1929
- Johnston v. CommissionerUnited States Tax Court · 1950
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