Legal Opinion

Glenwood Sanatorium v. Commissioner

United States Tax Court

Decided September 30, 1953No. Docket No. 36540Published

Rental expense accrued and set off by petitioner corporation against amounts previously advanced to landlord-stockholder so as to reduce the latter's liability thereon held not barred as a deductible expense by section 24 (c), Internal Revenue Code. Michael Flynn Mfg. Co., 3 T. C. 932, followed.

1Opinion of the Court

Glenwood Sanatorium, a Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Glenwood Sanatorium v. Commissioner

Docket No. 36540

United States Tax Court

20 T.C. 1099; 1953 U.S. Tax Ct. LEXIS 56;

September 30, 1953, Promulgated

Decision will be entered for the petitioner.

Rental expense accrued and set off by petitioner corporation against amounts previously advanced to landlord-stockholder so as to reduce the latter's liability thereon held not barred as a deductible expense by section 24 (c), Internal Revenue Code. Michael Flynn Mfg. Co., 3 T. C. 932, followed.

R. Shad Bennett,…

2Cases cited10 opinions

  1. Acer Realty Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1942
  2. Michael Flynn Mfg. Co. v. CommissionerUnited States Tax Court · 1944
  3. Anthony P. Miller, Inc. v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1947
  4. Ohio Battery & Ignition Co. v. CommissionerUnited States Tax Court · 1945
  5. PG Lake, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1945

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