Legal Opinion

H. E. Fletcher Co. v. Comm'r

United States Tax Court

Decided October 26, 1951No. Docket No. 28105Unpublished

1. Held, notes issued by a corporation in exchange for preferred stock of that corporation constituted indebtedness, and the interest paid thereon was deductible. 2. Held, attorney's fees which were paid as ordinary and necessary business expenses were deductible. 3. Held, interest paid on uncontested additional assessments of State and Federal taxes could be deducted by a corporation on the accrual basis in the year to which the tax related.

1Opinion of the Court

H. E. Fletcher Company v. Commissioner.

H. E. Fletcher Co. v. Comm'r

Docket No. 28105.

United States Tax Court

1951 Tax Ct. Memo LEXIS 57; 10 T.C.M. (CCH) 1025; T.C.M. (RIA) 51317;

October 26, 1951

1. Held, notes issued by a corporation in exchange for preferred stock of that corporation constituted indebtedness, and the interest paid thereon was deductible.

2. Held, attorney's fees which were paid as ordinary and necessary business expenses were deductible.

3. Held, interest paid on uncontested additional assessments of State and Federal taxes could be deducted by a corporation on the accrual basis…

2Cases cited9 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
  3. Lehigh v. R. Co. v. CommissionerUnited States Tax Court · 1949
  4. H. E. Harman Coal Corp. v. CommissionerUnited States Tax Court · 1951
  5. Cleveland Adolph Mayer Realty Corp. v. CommissionerUnited States Tax Court · 1946

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