Legal Opinion

Remington Typewriter Co. v. Commissioner

United States Board of Tax Appeals

Decided September 22, 1926No. Docket No. 2788PublishedCited by 8 opinions

Upon the evidence, held, that debts owing to petitioner by certain foreign subsidiaries which it charged off during the year 1918 were worthless and constituted proper deductions from gross income for that year; also that petitioner's investments in corporations in Germany and Austria-Hungary were worthless on December 31, 1918, and were deductible as losses sustained within that year.

1Opinion of the Court

*884OPINION.

Littleton:

There is no controversy with respect to the correctness of the amount of the investment in foreign subsidiary companies, nor the amounts owing from them on account of money advanced and merchandise sold. The questions presented are: (1) Was the Remington Typewriter Company of New York entitled to a deduction from gross income for 1918, on account of debts owing to it by certain of its foreign subsidiaries, which it alleges were charged off during that year ? (2) Was the Remington Typewriter Company of New York entitled to a deduction from gross income for 1918 on account of…

2Cases cited3 opinions

  1. Williams v. HeardSupreme Court of the United States · 1891
  2. United States v. WeldSupreme Court of the United States · 1888
  3. S. S. White Dental Manufacturing Co. v. United StatesUnited States Court of Claims · 1925

3Cited by8 opinions

  1. Halliburton Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1991
  2. Halliburton Co. v. CommissionerUnited States Tax Court · 1989
  3. Colish v. CommissionerUnited States Tax Court · 1967
  4. Brigham v. United StatesDistrict Court, D. Massachusetts · 1941
  5. FLINT INDUS. v. COMMISSIONERUnited States Tax Court · 2001

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