Jorden v. Commissioner
United States Tax Court
1. Prior to October 15, 1940, corporation A held a demand note of the face value of $ 621,000 and all of the capital stock of corporation B. Petitioner was the manager of corporation B. Pursuant to a contract of that date between corporation A, corporation B, and the petitioner, corporation A agreed to sell and transfer to petitioner the note and shares of corporation B, provided corporation B and petitioner would pay it the sum of $ 145,500 in stated payments as a…
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1. Prior to October 15, 1940, corporation A held a demand note of the face value of $ 621,000 and all of the capital stock of corporation B. Petitioner was the manager of corporation B. Pursuant to a contract of that date between corporation A, corporation B, and the petitioner, corporation A agreed to sell and transfer to petitioner the note and shares of corporation B, provided corporation B and petitioner would pay it the sum of $ 145,500 in stated payments as a curtailment of the note. Upon the payment of the sum agreed upon, said payments were credited by corporation A against the…
1Opinion of the Court
Arundell, Judge:
The proceeding under Docket No. 13704 involves a deficiency in the petitioner’s income tax for the calendar year 1941 in the amount of $73,574.03, and a deficiency in income and victory taxes for the calendar year 1943 in the amount of $84,834.86.
The proceeding under Docket No. 13735 involves deficiencies in income, declared value excess profits, and excess profits taxes determined against the petitioner as a fiduciary for the Bemidji Wood Products Co. for the taxable years ended December 31,1941 and 1942. The deficiencies in income tax determined for 1941 and 1942 are…
2Cases cited2 opinions
- Janeway v. CommissionerUnited States Tax Court · 1943
- Aldrich v. CommissionerUnited States Tax Court · 1943
3Cited by22 opinions
- Fahs v. MartinCourt of Appeals for the Fifth Circuit · 1955
- Liflans Corporation v. The United StatesUnited States Court of Claims · 1968
- Illinois Power Co. v. CommissionerUnited States Tax Court · 1986
- Cohen v. CommissionerUnited States Tax Court · 1954
- Braddock Land Co. v. CommissionerUnited States Tax Court · 1980
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