Samuel Goldwyn, Inc. v. Commissioner
United States Board of Tax Appeals
1. In order to secure the deduction authorized by section 351(b)(2)(B) of the Revenue Act of 1934, the indebtedness must have been incurred prior to January 1, 1934, by the taxpayer. 2. A penalty of 25 percent for late filing of a return must be sustained under section 406 of the Revenue Act of 1935 where no reasonable cause for the tardiness is shown.
1Opinion of the Court
*1087OPINION.
Leech :
In this proceeding the petitioner, Samuel Goldwyn Inc., Ltd., admits transferee liability in respect of any deficiency that may be determined against the petitioner, United Artists Studio Inc. The word “petitioner” as hereinafter used refers to the latter. Respondent has determined a deficiency of $4,055.82 in petitioner’s personal holding company surtax for the fiscal year ended June 30,1936, and a penalty of $1,013.96. The issues are whether petitioner is entitled to deduct $16,600 from its adjusted net income as an amount used to retire indebtedness incurred prior to January…
2Cases cited1 opinion
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
3Cited by7 opinions
- Aptitude Associates, Inc. v. CommissionerUnited States Tax Court · 1962
- Belaieff v. CommissionerUnited States Tax Court · 1956
- Knight Newspapers, Inc. v. CommissionerUnited States Tax Court · 1943
- Lancer Clothing Corp. v. CommissionerUnited States Tax Court · 1975
- Orient Inv. & Fin. Co. v. CommissionerUnited States Tax Court · 1947
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