James A. Messer Co. v. Commissioner
United States Tax Court
1. In 1965 petitioner completed the liquidation of a valid, unsecured debt owed to it by an insolvent sibling corporation, and claimed a bad debt deduction with respect thereto.
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1. In 1965 petitioner completed the liquidation of a valid, unsecured debt owed to it by an insolvent sibling corporation, and claimed a bad debt deduction with respect thereto. Respondent disallowed the deduction, asserting that the debt had actually become wholly worthless, and hence deductible, prior to 1965. Held, the identifiable events marking the worthlessness of the debt occurred in 1965. Held, further, respondent's argument based on the allegation that petitioner artificially ordered the affairs of itself and its debtor solely with the aim of achieving the optimum tax results must…
1Opinion of the Court
James A. Messer Company, Petitioner v. Commissioner of Internal Revenue, Respondent
James A. Messer Co. v. Commissioner
Docket No. 4130-69
United States Tax Court
57 T.C. 848; 1972 U.S. Tax Ct. LEXIS 158;
March 23, 1972, Filed
Decision will be entered under Rule 50.
1. In 1965 petitioner completed the liquidation of a valid, unsecured debt owed to it by an insolvent sibling corporation, and claimed a bad debt deduction with respect thereto. Respondent disallowed the deduction, asserting that the debt had actually become wholly worthless, and hence deductible, prior to 1965. Held, the identifiable…
2Cases cited27 opinions
- Boehm v. CommissionerSupreme Court of the United States · 1945
- Avery v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1927
- Black Motor Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
- Black Motor Co. v. CommissionerUnited States Board of Tax Appeals · 1940
- Denver & Rio Grande Western Railroad Company v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1960
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