Legal Opinion
Byerlite Corporation v. Parker C. Williams, District Director of Internal Revenue, Eighteenth District of Ohio
Court of Appeals for the Sixth Circuit
Decided December 15, 1960No. 13877_1PublishedCited by 83 opinions
1Opinion of the Court
McALLISTER, Chief Judge.
Plaintiff paid income and excess profits taxes for 1949 and 1950 under protest, and brought this action to recover them. It contended that certain advances which it made to an affiliated corporation were loans; that these loans were not repaid; that they, therefore, constituted a bad debt; and that, accordingly, they were deductible, as a bad debt, from plaintiff’s ordinary income, under Section 23 (k) of the Internal Revenue Code of 1939, 26 U.S.C.A. § 23 (k).
The District Court held that the advances in question from plaintiff to its affiliated corporation were not…
2Cases cited13 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Peurifoy v. CommissionerSupreme Court of the United States · 1958
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- John v. Rowan v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Kraft Foods Company v. Commissioner of Internal Revenue, (Two Cases)Court of Appeals for the Second Circuit · 1956
8 more not listed; retrieve them via the Exa API.
3Cited by83 opinions
- Litton Business Systems, Inc. v. CommissionerUnited States Tax Court · 1973
- Jack Daniel Distillery, Lem Motlow, Prop., Inc. v. The United StatesUnited States Court of Claims · 1967
- Santa Anita Consol., Inc. v. CommissionerUnited States Tax Court · 1968
- Magnon v. CommissionerUnited States Tax Court · 1980
- C. M. Gooch Lumber Sales Co. v. CommissionerUnited States Tax Court · 1968
78 more not listed; retrieve them via the Exa API.