Standard Oil Co. v. Commissioner
United States Tax Court
During 1936 and prior to the liquidation of Standard Oil Export Corporation, petitioner and the other guarantors of this corporation's preferred stock dividends were called upon to pay the final dividend on Export's preferred stock.
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During 1936 and prior to the liquidation of Standard Oil Export Corporation, petitioner and the other guarantors of this corporation's preferred stock dividends were called upon to pay the final dividend on Export's preferred stock. Held, any claim petitioner had against Export for reimbursement of its share of the final dividend which it paid in 1936 was worthless in 1936; held, further, petitioner is entitled to deduct, either as an expense or loss in the taxable year 1936, that part of the amount paid in 1936 for which it was liable under its contract of guaranty, which liability is…
1Opinion of the Court
SUPPLEMENTAL OPINION.
Black, Judge:
As stated in our earlier report (7 T. C. 1310) petitioner contends that it is entitled to deduct the entire amount of $764,914.24, either as a business expense or as a loss. The respondent contends primarily that no part of the payment of $764,914.24 is so deductible, and in the alternative that, if any amount is deductible, the amount deductible can not be in excess of $350,139.21. This alternative contention is based upon the further contention that the $6,799,446.67 distributed by Anglo out of its earned surplus on hand on December 31, 1929, was available…
2Cases cited4 opinions
- American Surety Co. v. Westinghouse Electric Manufacturing Co.Supreme Court of the United States · 1935
- Jenkins v. National Surety Co.Supreme Court of the United States · 1928
- Camp Mfg. Co. v. CommissionerUnited States Tax Court · 1944
- Cunningham v. NortonSupreme Court of the United States · 1888
3Cited by12 opinions
- Intergraph Corp. v. CommissionerUnited States Tax Court · 1996
- The United Gas Improvement Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1956
- Nalco Chemical Co. v. United StatesDistrict Court, N.D. Illinois · 1983
- McJunkin v. CommissionerUnited States Tax Court · 1955
- Estate of McJunkin v. CommissionerUnited States Tax Court · 1955
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