Pondfield Realty Co. v. Commissioner
United States Tax Court
A forgiveness by an employee of a debt for salary for past services which had accrued and been deducted in an earlier year by the corporation on an accrual basis but not returned as income by the employee on a cash basis held taxable to the corporation as realized income in the year of forgiveness even though the employee is a shareholder.
1Opinion of the Court
OPINION.
Sternhagen, Judge:
Determining a deficiency of $482.51 income tax for 1939, the Commissioner held that the cancellation of $3,750 indebtedness for salaries due officers constituted taxable income. The proceeding was submitted under Rule 30 upon a stipulation of facts.
The petitioner is a New York corporation and filed its 1939 income and excess profits tax return in the third district of New York; Its assets consist entirely of a one-story business building in Westchester County and its income since incorporation has been only the rents therefrom. Its shares were held one-third by…
2Cases cited1 opinion
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
3Cited by6 opinions
- George Hall Corp. v. CommissionerUnited States Tax Court · 1943
- Commissioner of Internal Revenue v. Fender Sales, Inc., Commissioner of Internal Revenue v. Donald D. And Jean Randall, Commissioner of Internal Revenue v. Esther Fender, Commissioner of Internal Revenue v. Jean E. Randall, Commissioner of Internal Revenue v. Donald D. Randall, Commissioner of Internal Revenue v. E. Leo FenderCourt of Appeals for the Ninth Circuit · 1965
- Commissioner v. Fender Sales, Inc.Court of Appeals for the Ninth Circuit · 1964
- George Hall Corp. v. CommissionerUnited States Tax Court · 1943
- George Hall Corp. v. CommissionerUnited States Tax Court · 1943
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