P. F. Scheidelman & Sons, Inc. v. Commissioner
United States Tax Court
1. In 1954 petitioner issued 4 1/2 percent notes in redemption of its seven percent cumulative preferred stock. A maximum of 10 percent of the principal was payable annually on demand. The corporation reserved the right to prepay the notes in whole or in part. The notes were not subordinated to other creditors, interest and principal were unconditionally payable, and the notes were completely paid within five years of issuance.
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1. In 1954 petitioner issued 4 1/2 percent notes in redemption of its seven percent cumulative preferred stock. A maximum of 10 percent of the principal was payable annually on demand. The corporation reserved the right to prepay the notes in whole or in part. The notes were not subordinated to other creditors, interest and principal were unconditionally payable, and the notes were completely paid within five years of issuance. Petitioner paid and claimed deductions for interest during the period the notes were outstanding. Respondent disallowed such deductions. Held: That the notes…
1Opinion of the Court
P. F. Scheidelman & Sons, Inc. v. Commissioner.
P. F. Scheidelman & Sons, Inc. v. Commissioner
Docket Nos. 90022, 92327, 4324-62.
United States Tax Court
T.C. Memo 1965-31; 1965 Tax Ct. Memo LEXIS 298; 24 T.C.M. (CCH) 168; T.C.M. (RIA) 65031;
February 17, 1965
1. In 1954 petitioner issued 4 1/2 percent notes in redemption of its seven percent cumulative preferred stock. A maximum of 10 percent of the principal was payable annually on demand. The corporation reserved the right to prepay the notes in whole or in part. The notes were not subordinated to other creditors, interest and principal were…
2Cases cited21 opinions
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Commissioner of Internal Revenue v. Proctor ShopCourt of Appeals for the Ninth Circuit · 1936
- Krim-Ko Corp. v. CommissionerUnited States Tax Court · 1951
- United States v. Title Guarantee & Trust Co.Court of Appeals for the Sixth Circuit · 1943
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3Cited by1 opinion
- Schochet v. CommissionerUnited States Tax Court · 1982