Legal Opinion

Arlington Park Jockey Club, Inc. v. Sauber

Court of Appeals for the Seventh Circuit

Decided February 2, 1959No. Nos. 12453, 12454PublishedCited by 21 opinions

1Opinion of the Court

DUFFY, Chief Judge.

Plaintiffs each brought a suit to recover corporate income taxes paid for the year 1948. The two cases were consolidated for trial. The question before us is whether plaintiffs may deduct as bad debts the sum of $227,225.71 which each advanced or loaned to a wholly-owned subsidiary in an unsuccessful effort to put the subsidiary on a self-sustaining business basis.

The Commissioner of Internal Revenue disallowed the deductions as bad debts and treated the amounts advanced as contributions to capital and, therefore, deductible only as long term capital losses. The decision of…

2Cases cited6 opinions

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
  3. White v. United StatesSupreme Court of the United States · 1938
  4. Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
  5. Schnitzer v. CommissionerUnited States Tax Court · 1949

1 more not listed; retrieve them via the Exa API.

3Cited by21 opinions

  1. Sherwood Memorial Gardens, Inc., (Tennessee) v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1965
  2. Carl G. Ortmayer and Hilda B. Ortmayer, Husband and Wife v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1959
  3. Kohler-Campbell Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1962
  4. National Farmers Union Service Corporation v. United StatesCourt of Appeals for the Tenth Circuit · 1968
  5. Portage Plastics Company v. United StatesDistrict Court, W.D. Wisconsin · 1969

16 more not listed; retrieve them via the Exa API.

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