Legal Opinion
Kraft Foods Company v. Commissioner of Internal Revenue, (Two Cases)
Court of Appeals for the Second Circuit
Decided April 2, 1956No. 7, 8, Docket 23224, 23225PublishedCited by 109 opinions
1Opinion of the Court
WATERMAN, Circuit Judge.
The sole issue raised by this appeal from a decision of the Tax Court, 1954, 21 T.C. 513, is whether so-called debenture interest payments made by the taxpayer corporation, Kraft Foods Company, to its parent corporation and sole stockholder, National Dairy Products Corporation, during the years 1934 to 1938, inclusive, constituted deductible “interest * * * on indebtedness”' within the meaning of Section 23(b) of the Revenue Acts of 1934, 1936, and 1938, 26 U.S.C.A. (I.R.C.1939) § 23(b). Jurisdiction is conferred on this Court by Section 1141(a) of the Internal Reve*121nue…
2Cases cited58 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Pepper v. LittonSupreme Court of the United States · 1939
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
53 more not listed; retrieve them via the Exa API.
3Cited by109 opinions
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Recklitis v. CommissionerUnited States Tax Court · 1988
- Estate of Travis Mixon, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
- Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner, in No. 97-7484 v. Commissioner of Internal Revenue Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner v. Commissioner of Internal Revenue, in No. 97-7527Court of Appeals for the Third Circuit · 1998
- Alterman Foods, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1975
104 more not listed; retrieve them via the Exa API.