Legal Opinion
Prudence Securities Corporation v. Com'r of Int. Rev.
Court of Appeals for the Second Circuit
Decided March 30, 1943No. 158PublishedCited by 15 opinions
1Opinion of the Court
FRANK, Circuit Judge.
The B bonds, accrued interest on which taxpayer seeks to deduct, are owned by a corporation which also owns all taxpayer’s stock. A corporation, ordinarily, cannot in a real sense become a creditor of one of its own incorporated departments. The situation here is substantially the same as if the taxpayer were seeking to deduct accrued interest on its own unissued bonds because it had set them aside in an envelope in its vault. While there are perhaps conceivable circumstances in which accruing interest on bonds of a wholly owned subsidiary held by its parent company might…
2Cases cited6 opinions
- Higgins v. SmithSupreme Court of the United States · 1940
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Lucas v. North Texas Lumber Co.Supreme Court of the United States · 1930
- Jamaica Water Supply Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1942
- Zimmerman Steel Co. v. Commissioner of Int. Rev.Court of Appeals for the Eighth Circuit · 1942
1 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Kraft Foods Company v. Commissioner of Internal Revenue, (Two Cases)Court of Appeals for the Second Circuit · 1956
- Guardian Investment Corporation v. Robert L. Phinney, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
- Fahs v. MartinCourt of Appeals for the Fifth Circuit · 1955
- P. M. Finance Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
- Burlington-Rock Island Railroad Company v. United StatesCourt of Appeals for the Fifth Circuit · 1963
10 more not listed; retrieve them via the Exa API.