Legal Opinion

American Dental Co. v. Commissioner

United States Board of Tax Appeals

Decided May 7, 1941No. Docket No. 102977Published

INCOME - FORGIVENESS OF INDEBTEDNESS. - Forgiveness of debts for back rent and accrued interest, held, to have taken place in the taxable year rather than prior thereto; the forgiveness was not a gift; and the resulting tax liability need not be limited to the tax benefit measured in dollars received by the taxpayer in prior years when it claimed deductions on an accrual method for the rent and interest.

1Opinion of the Court

AMERICAN DENTAL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

American Dental Co. v. Commissioner

Docket No. 102977.

United States Board of Tax Appeals

44 B.T.A. 425; 1941 BTA LEXIS 1330;

May 7, 1941, Promulgated

INCOME - FORGIVENESS OF INDEBTEDNESS. - Forgiveness of debts for back rent and accrued interest, held, to have taken place in the taxable year rather than prior thereto; the forgiveness was not a gift; and the resulting tax liability need not be limited to the tax benefit measured in dollars received by the taxpayer in prior years when it claimed deductions on an…

2Cases cited9 opinions

  1. United States v. Kirby Lumber CoSupreme Court of the United States · 1931
  2. Block v. CommissionerUnited States Board of Tax Appeals · 1939
  3. Lakeland Grocery Co. v. CommissionerUnited States Board of Tax Appeals · 1937
  4. Denny v. CommissionerUnited States Board of Tax Appeals · 1935
  5. Central Loan & Inv. Co. v. CommissionerUnited States Board of Tax Appeals · 1939

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