Legal Opinion

Ewing v. Commissioner

United States Tax Court

Decided November 29, 1956No. Docket Nos. 54231, 54232, 54233, 54234Published

Income Tax -- Deductions. -- Held, that amounts paid by the petitioners, as transferees, in satisfaction of the transferor corporation's tax liability are deductible as capital losses, and not as ordinary losses.

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Income Tax -- Deductions. -- Held, that amounts paid by the petitioners, as transferees, in satisfaction of the transferor corporation's tax liability are deductible as capital losses, and not as ordinary losses. Arrowsmith v. Commissioner, 344 U.S. 60. Held, further, that amounts paid by them, as transferees, in satisfaction of the liability of the corporation for interest on its tax liability accrued prior to the date of transfer of assets of the corporation to them are not deductible by them as interest, but are deductible as capital losses.

1Opinion of the Court

Floyd C. Ewing and Leah E. Ewing, et al., * Petitioners, v. Commissioner of Internal Revenue, Respondent

Ewing v. Commissioner

Docket Nos. 54231, 54232, 54233, 54234

United States Tax Court

27 T.C. 406; 1956 U.S. Tax Ct. LEXIS 30;

November 29, 1956, Filed

Decisions will be entered for the respondent.

Income Tax -- Deductions. -- Held, that amounts paid by the petitioners, as transferees, in satisfaction of the transferor corporation's tax liability are deductible as capital losses, and not as ordinary losses. Arrowsmith v. Commissioner, 344 U.S. 60. Held, further, that amounts paid by them, as…

2Cases cited6 opinions

  1. Healy v. CommissionerSupreme Court of the United States · 1953
  2. Arrowsmith v. CommissionerSupreme Court of the United States · 1952
  3. Leach v. CommissionerUnited States Tax Court · 1953
  4. Koppers Co. v. CommissionerUnited States Tax Court · 1944
  5. Johnson v. CommissionerUnited States Tax Court · 1952

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