Legal Opinion
First Mortgage Corp. v. Commissioner of Internal Rev.
Court of Appeals for the Third Circuit
Decided April 20, 1943No. 8108PublishedCited by 15 opinions
1Opinion of the Court
MARIS, Circuit Judge.
This is a petition to review a decision of the Board of Tax Appeals. First Mortgage Corporation of Philadelphia, the petitioner, claimed deductions in its income tax returns for the years 1936 and 1937 for payments made to its preferred stockholders in those years. It claimed these payments to be interest upon its indebtedness and deductible as such by virtue of section 23(b) of the Revenue Act of 1936, 26 U.S. C.A. Int.Rev.Code, § 23(b), 1 and Treasury Regulation 94 promulgated thereunder. 2
The Commissioner of Internal Revenue determined that the payments were for…
2Cases cited11 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Warren v. KingSupreme Court of the United States · 1883
- Commissioner of Internal Revenue v. OPP Holding Corp.Court of Appeals for the Second Circuit · 1935
- Commissioner of Internal Revenue v. Proctor ShopCourt of Appeals for the Ninth Circuit · 1936
6 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Estate of Travis Mixon, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
- Gooding Amusement Co. v. CommissionerCourt of Appeals for the Sixth Circuit · 1956
- Miele v. CommissionerUnited States Tax Court · 1971
- John Wanamaker Philadelphia v. Com'r of Int. RevenueCourt of Appeals for the Third Circuit · 1943
- Crawford Drug Stores, Inc. v. United StatesCourt of Appeals for the Tenth Circuit · 1955
10 more not listed; retrieve them via the Exa API.