Legal Opinion
Piedmont Minerals Company, Inc. v. United States
Court of Appeals for the Fourth Circuit
Decided July 29, 1970No. 13677_1PublishedCited by 21 opinions
1Opinion of the Court
HAYNSWORTH, Chief Judge:
In this appeal we are faced with the oft-litigated question of whether advances made to a corporation by its principal stockholders constituted capital or debt for federal income tax purposes. The district court found the advances to be debt, and we affirm.
The historical facts are undisputed.
In 1934 John A. Boren and E. M. Harvey organized a small manufacturing .plant to produce refractory products. This business, incorporated in 1938 as North State Pyrophyllite Company, Inc., prospered. Since the source of ore supply owned by North State was approaching exhaustion, a…
2Cases cited4 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Michael Berkowitz and Harris Kolbert, as Last Directors and Liquidating Trustees of K & B Trail Properties, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1969
- Road Materials, Inc. v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Road Materials, Inc.Court of Appeals for the Fourth Circuit · 1969
- Jewell Ridge Coal Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1963
3Cited by21 opinions
- Peter J. Brennan, Secretary of Labor, United States Department of Labor v. Prince William Hospital CorporationCourt of Appeals for the Fourth Circuit · 1974
- Bobby E. Welch and Kathleen Newman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2000
- Indmar Products Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2006
- Famous Knitwear Corporation v. Drug Fair, Inc., Famous Knitwear Corporation v. Drug Fair, Inc.Court of Appeals for the Fourth Circuit · 1974
- Estate of Lennard v. CommissionerUnited States Tax Court · 1974
16 more not listed; retrieve them via the Exa API.