Rodney, Inc. v. Commissioner
United States Tax Court
Petitioner corporation was organized by A for the purpose of acquiring all of the stock of X, a foreign personal holding corporation, which had been organized by A some years before. A had transferred certain securities to X in return for X's stock and serial debentures bearing interest payable upon the maturity of the debentures.
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Petitioner corporation was organized by A for the purpose of acquiring all of the stock of X, a foreign personal holding corporation, which had been organized by A some years before. A had transferred certain securities to X in return for X's stock and serial debentures bearing interest payable upon the maturity of the debentures. Events having transpired which made X's existence no longer necessary, it was decided by petitioner, petitioner's sole stockholder, A, and X that X should transfer all of its assets to petitioner to be held by petitioner instead of by X, that petitioner would…
1Opinion of the Court
OPINION.
Kern, Judge:
The single question presented for decision here is whether petitioner is entitled to a deduction for interest paid by it on obligations issued by a corporation all of the stock of which was owned by petitioner and which was later liquidated, its obligations, including the bonds, principal and interest, being assumed by petitioner.
The applicable section of the Revenue Act of 1938 is as follows:
SEC. 2 3. DEDUCTIONS FROM GROSS INCOME.
In computing net income there shall be allowed as deductions:
*******(b) Interest. — All interest paid or accrued within the taxable year on…
2Cited by11 opinions
- Thompson v. CommissionerUnited States Tax Court · 1976
- Hearst Corp. v. CommissionerUnited States Tax Court · 1950
- Family Group, Inc. v. CommissionerUnited States Tax Court · 1973
- Baldwin v. CommissionerUnited States Tax Court · 1955
- Philadelphia Transp. Co. v. CommissionerUnited States Tax Court · 1947
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