Legal Opinion
Roth Steel Tube Company v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided September 10, 1986No. 85-1656PublishedCited by 105 opinions
1Opinion of the Court
MILBURN, Circuit Judge.
Roth Steel Tube Company (“taxpayer”) appeals from a decision of the United States Tax Court sustaining deficiencies in the amount of $1,728,802 determined by the Commissioner of Internal Revenue (“the Commissioner”) with respect to taxpayer’s federal income tax liability for the taxable years 1971 through 1975. The principal issue presented is whether taxpayer’s unrepaid advances to a subsidiary corporation were loans deductible as bad debts under 26 U.S.C. § 166 or capital contributions deductible only to the extent of capital gains under 26 U.S.C. § 1221. Because the…
2Cases cited20 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Estate of Travis Mixon, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
- Adolph Coors Company v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1975
- Paul W. Berthold and Dorothy Berthold v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1968
15 more not listed; retrieve them via the Exa API.
3Cited by105 opinions
- Taft Broadcasting Company v. United StatesCourt of Appeals for the Sixth Circuit · 1991
- James L. Rose and Judy S. Rose v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1989
- Elec. Arts, Inc. v. Comm'rUnited States Tax Court · 2002
- Frank C. Pasternak Judith Pasternak (92-1681/1682) Anthony J. Cutaia Diane Cutaia David G. Koehlinger (92-1681) v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1993
- Adelphia Communications Corp. v. Bank of America, N.A. (In Re Adelphia Communications Corp.)United States Bankruptcy Court, S.D. New York · 2007
100 more not listed; retrieve them via the Exa API.