Legal Opinion

O'NEILL v. Commissioner of Internal Revenue

Court of Appeals for the Second Circuit

Decided November 12, 1948No. 10, Docket 20915PublishedCited by 16 opinions

1Opinion of the Court

CHASE, Circuit Judge.

The- petitioner, a practicing lawyer residing in New Jersey and having offices in the City of New York, filed his income tax return for the calendar year 1941 with the Collector of Internal Revenue for the Second District of New York. In it he took as deductions for bad debts, relying on § 23 (k). of the Internal Revenue Code, 26 U.S.C.A. § 23(k), the full amount of the unpaid remainder of advances he had made over a period of years to two corporations, wholly owned by him, which were dissolved in 1941 and were both insolvent if those advances were debts. The Commissioner…

2Cases cited14 opinions

  1. Higgins v. SmithSupreme Court of the United States · 1940
  2. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  3. Burnet v. Commonwealth Improvement Co.Supreme Court of the United States · 1932
  4. National Investors Corporation v. HoeyCourt of Appeals for the Second Circuit · 1944
  5. Paymer v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945

9 more not listed; retrieve them via the Exa API.

3Cited by16 opinions

  1. Kraft Foods Company v. Commissioner of Internal Revenue, (Two Cases)Court of Appeals for the Second Circuit · 1956
  2. Bolger v. CommissionerUnited States Tax Court · 1973
  3. Herbert v. RiddellDistrict Court, S.D. California · 1952
  4. Commissioner of Internal Revenue v. State-Adams CorporationCourt of Appeals for the Second Circuit · 1960
  5. Pacific Magnesium, Inc. v. WestoverDistrict Court, S.D. California · 1949

11 more not listed; retrieve them via the Exa API.

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