Legal Opinion
The Gregg Company of Delaware v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided December 17, 1956No. 2, Docket 23621PublishedCited by 21 opinions
1Opinion of the Court
WATERMAN, Circuit Judge.
The petitioner, The Gregg Company of Delaware, appeals from a decision of the Tax Court, 23 T.C. 170, 1954, that the amounts paid by petitioner to its parent corporation on its so-called “Fifty-Year 4% Income Notes” were not deductible “interest * * * on indebtedness” within the meaning of Section 23(b) of the Revenue Acts of 1934, 1936, and 1938, 26 U.S.C.A. (I.R.C.1939) § 23(b). Petitioner asserts that these Notes were evidence of a valid indebtedness and therefore it was entitled to a tax deduction for the payment of interest thereon.
We believe the Tax Court was so…
2Cases cited6 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Kraft Foods Company v. Commissioner of Internal Revenue, (Two Cases)Court of Appeals for the Second Circuit · 1956
- National Investors Corporation v. HoeyCourt of Appeals for the Second Circuit · 1944
- Gregg Co. of Delaware v. CommissionerUnited States Tax Court · 1954
1 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- P. M. Finance Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
- T. M. Britt and Jane Britt v. The United States of AmericaCourt of Appeals for the Fifth Circuit · 1970
- Tifd Iii-E, Inc. v. United States of America, Docket No. 05-0064-CvCourt of Appeals for the Second Circuit · 2006
- Commissioner of Internal Revenue v. State-Adams CorporationCourt of Appeals for the Second Circuit · 1960
16 more not listed; retrieve them via the Exa API.