Legal Opinion
John Kelley Co. v. Commissioner
Supreme Court of the United States
Decided January 7, 1946No. Nos. 36, 47PublishedCited by 428 opinions
1Opinion of the Court
Opinion of the Court by
Mr. Justice Reed,
announced by Mr. Justice Frankfurter.
These writs of certiorari were granted to examine the deductibility as interest of certain payments which the taxpayer corporations made to holders of their corporate obligations. Although the obligations of the two taxpayers had only one striking difference, the noncumulative in one and the cumulative quality in the other of the payments reserved under the characterization of interest, the Tax Court (formerly the Board of Tax Appeals, 56 Stat. 957; only its present name will be used herein) held that the payments…
2Cases cited24 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Gregory v. HelveringSupreme Court of the United States · 1935
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Helvering v. HallockSupreme Court of the United States · 1940
- Dobson v. CommissionerSupreme Court of the United States · 1944
19 more not listed; retrieve them via the Exa API.
3Cited by428 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Enoch v. CommissionerUnited States Tax Court · 1972
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Recklitis v. CommissionerUnited States Tax Court · 1988
423 more not listed; retrieve them via the Exa API.