Legal Opinion

Zilkha & Sons, Inc. v. Commissioner

United States Tax Court

Decided July 2, 1969No. Docket Nos. 1902-66, 1995-66Published

Held, certain corporate securities owned by the petitioners are stock, not debt, and accordingly, payments received by the petitioners on account of such securities are distributions with respect to stock and not interest.

1Opinion of the Court

Zilkha & Sons, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent; Jerome L. Stern and Jane Stern, Petitioners v. Commissioner of Internal Revenue, Respondent

Zilkha & Sons, Inc. v. Commissioner

Docket Nos. 1902-66, 1995-66

United States Tax Court

52 T.C. 607; 1969 U.S. Tax Ct. LEXIS 96;

July 2, 1969, Filed

Decisions will be entered under Rule 50.

Held, certain corporate securities owned by the petitioners are stock, not debt, and accordingly, payments received by the petitioners on account of such securities are distributions with respect to stock and not interest.

Victor S. Friedman,…

2Cases cited17 opinions

  1. Santa Anita Consol., Inc. v. CommissionerUnited States Tax Court · 1968
  2. United States v. South Georgia Ry. Co.Court of Appeals for the Fifth Circuit · 1939
  3. Ernst Kern Co. v. CommissionerUnited States Tax Court · 1942
  4. Ambassador Apartments, Inc. v. CommissionerUnited States Tax Court · 1968
  5. Ambassador Apartments, Inc. v. Commissioner of Internal Revenue, Louis Litoff and Rose Litoff v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969

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