Jackson Finance & Thrift Co. v. Commissioner
United States Tax Court
Held, amounts received by petitioners represented by thrift certificates issued to customers do not qualify as borrowed capital within the purview of section 439 (b) (1), I. R. C. 1939.
1Opinion of the Court
Jackson Finance and Thrift Company, Petitioner, v. Commissioner of Internal Revenue, Respondent. Ford Finance Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Jackson Finance & Thrift Co. v. Commissioner
Docket Nos. 60387, 60525
United States Tax Court
29 T.C. 272; 1957 U.S. Tax Ct. LEXIS 40;
November 19, 1957, Filed
Decisions will be entered under Rule 50.
Held, amounts received by petitioners represented by thrift certificates issued to customers do not qualify as borrowed capital within the purview of section 439 (b) (1), I. R. C. 1939.
Sanford M. Stoddard, Esq., for the…
Also in this document: Dissent.
2Cases cited10 opinions
- Economy Sav. & Loan Co. v. CommissionerUnited States Tax Court · 1945
- Journal Publishing Co. v. CommissionerUnited States Tax Court · 1944
- Economy Savings & Loan Co. v. Commissioner of Int. Rev.Court of Appeals for the Sixth Circuit · 1946
- Commissioner of Internal Revenue v. Ames Trust & Sav. BankCourt of Appeals for the Eighth Circuit · 1950
- Capital Nat'l Bank v. CommissionerUnited States Tax Court · 1951
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