Rosenblatt v. Commissioner
United States Tax Court
Petitioner, one of the shareholders and bondholders of a corporation, was in 1938 indebted to the corporation by reason of prior borrowing from the corporation. The remaining stockholders and bondholders were also indebted to the corporation but in varying and lesser amounts. Interest at 6 per cent based on the average borrowings of all stockholders was adjusted among the accounts of the stockholders.
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Petitioner, one of the shareholders and bondholders of a corporation, was in 1938 indebted to the corporation by reason of prior borrowing from the corporation. The remaining stockholders and bondholders were also indebted to the corporation but in varying and lesser amounts. Interest at 6 per cent based on the average borrowings of all stockholders was adjusted among the accounts of the stockholders. In December 1938 petitioner and the remaining stockholders conveyed all of the assets of the corporation, including the claims of the corporation against petitioner and the remaining…
1Opinion of the Court
Gertrude Rosenblatt, Petitioner, v. Commissioner of Internal Revenue, Respondent
Rosenblatt v. Commissioner
Docket No. 23719
United States Tax Court
16 T.C. 100; 1951 U.S. Tax Ct. LEXIS 314;
January 17, 1951, Promulgated
Decision will be entered under Rule 50.
Petitioner, one of the shareholders and bondholders of a corporation, was in 1938 indebted to the corporation by reason of prior borrowing from the corporation. The remaining stockholders and bondholders were also indebted to the corporation but in varying and lesser amounts. Interest at 6 per cent based on the average borrowings of all…
2Cases cited1 opinion
- Rosenblatt v. CommissionerUnited States Tax Court · 1951