Wisconsin Memorial Park Co. v. Commissioner
United States Tax Court
On June 21, 1934, petitioner was indebted to Kurtis R. Froedtert, its founder and owner of more than 50 per cent of its outstanding common (and preferred) stock, in an amount in excess of $ 400,000 -- and to other creditors in the aggregate amount of $ 100,000. On December 8, 1934, petitioner, Froedtert, and some other creditors entered into a debt compromise "Agreement" which recited that Froedtert, for valuable consideration received, quitclaimed, and assigned all of his…
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On June 21, 1934, petitioner was indebted to Kurtis R. Froedtert, its founder and owner of more than 50 per cent of its outstanding common (and preferred) stock, in an amount in excess of $ 400,000 -- and to other creditors in the aggregate amount of $ 100,000. On December 8, 1934, petitioner, Froedtert, and some other creditors entered into a debt compromise "Agreement" which recited that Froedtert, for valuable consideration received, quitclaimed, and assigned all of his right, title, and interest in and to the aforesaid stock to petitioner, and in turn transferred the stock to a trustee on…
1Opinion of the Court
Fisher, Judge:
These proceedings involve the following deficiencies in petitioner’s taxes determined by respondent:
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The following questions are presented by these proceedings:
1. Whether respondent properly determined that certain amounts of interest expense accrued annually by petitioner on its books could not be taker as deductions from gross income on its tax returns.
2. Wliethi r, as a result, respondent properly disallowed a deduction of a claimed net operating loss carryover for one of petitioner’s fiscal years.
FINDINGS OF FACT.
All facts í ipulated herein are incorporated by…
2Cases cited1 opinion
- Lexmont Corp. v. CommissionerUnited States Tax Court · 1953
3Cited by4 opinions
- Wisconsin Memorial Park Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1958
- Island Gas, Inc. v. CommissionerUnited States Tax Court · 1958
- Wisconsin Memorial Park Co. v. CommissionerUnited States Tax Court · 1957
- Wisconsin Memorial Park Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1958