Intergraph Corp. v. Commissioner
United States Tax Court
Held: Among other things, petitioner, in the year of payment, is not entitled to a claimed sec. 166, I.R.C., bad debt deduction with respect to its payment as guarantor of a Japanese-yen-denominated loan made to a Japanese subsidiary corporation.
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Held: Among other things, petitioner, in the year of payment, is not entitled to a claimed sec. 166, I.R.C., bad debt deduction with respect to its payment as guarantor of a Japanese-yen-denominated loan made to a Japanese subsidiary corporation. Where a guarantor has a right of subrogation against, or a right of reimbursement from, the primary obligor (regardless of whether that right is expressly stated in the guaranty agreement), the provisions of sec. 1.166-9(e)(2), Income Tax Regs., apply, and the guarantor is not entitled to a bad debt deduction until the right of subrogation, or the…
1Opinion of the Court
INTERGRAPH CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Intergraph Corp. v. Commissioner
Docket No. 21286-93.
United States Tax Court
106 T.C. 312; 1996 U.S. Tax Ct. LEXIS 17; 106 T.C. No. 16;
May 8, 1996, Filed
Decision will be entered for respondent.
Held: Among other things, petitioner, in the year of payment, is not entitled to a claimed sec. 166, I.R.C., bad debt deduction with respect to its payment as guarantor of a Japanese-yen-denominated loan made to a Japanese subsidiary corporation. Where a guarantor has a right of subrogation against, or a…
2Cases cited25 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Riss v. CommissionerUnited States Tax Court · 1971
- Richard R. Riss, Sr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1973
- Hynes v. CommissionerUnited States Tax Court · 1980
- Santa Anita Consol., Inc. v. CommissionerUnited States Tax Court · 1968
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