Legal Opinion

Johnson v. Commissioner

United States Tax Court

Decided December 12, 1952No. Docket Nos. 27949, 27950, 27951Published

1. During the taxable year petitioners as stockholder-transferees paid the taxes owed by a corporation completely liquidated in a prior year. Held, these payments constitute capital losses to petitioners, Arrowsmith v. Commissioner, 344 U.S. 6. 2. In addition to paying the tax deficiencies of the liquidated corporation, petitioners paid the interest accrued on the deficiencies.

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1. During the taxable year petitioners as stockholder-transferees paid the taxes owed by a corporation completely liquidated in a prior year. Held, these payments constitute capital losses to petitioners, Arrowsmith v. Commissioner, 344 U.S. 6. 2. In addition to paying the tax deficiencies of the liquidated corporation, petitioners paid the interest accrued on the deficiencies. Held, that as to so much of the interest accrued subsequent to corporate liquidation, the interest was that of petitioners and is deductible by them under section 23 (b) of the Code. 3. Petitioners held stock in one…

1Opinion of the Court

Elise Avery Johnson, Petitioner, v. Commissioner of Internal Revenue, Respondent. Courtney Glisson, Petitioner, v. Commissioner of Internal Revenue, Respondent. Estate of William Joe Godwin, Deceased, Ruth Godwin, Executrix, Petitioner, v. Commissioner of Internal Revenue, Respondent

Johnson v. Commissioner

Docket Nos. 27949, 27950, 27951

United States Tax Court

19 T.C. 465; 1952 U.S. Tax Ct. LEXIS 21;

December 12, 1952, Promulgated

Decisions will be entered under Rule 50.

1. During the taxable year petitioners as stockholder-transferees paid the taxes owed by a corporation completely liquidated in…

2Cases cited2 opinions

  1. Arrowsmith v. CommissionerSupreme Court of the United States · 1952
  2. Johnson v. CommissionerUnited States Tax Court · 1952

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