Legal Opinion
Lidgerwood Manufacturing Co. v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided January 17, 1956No. 18-3484PublishedCited by 33 opinions
1Opinion of the Court
SWAN, Circuit Judge,
The question presented by this appeal is whether the Tax Court erred in hold ing that the taxpayer’s cancellation in 1946 of debts owed to it by two subsidiary corporations, whose stock was wholly owned by it, constituted capital contributions to the subsidiaries and precluded deduction as worthless debts of the amounts, aggregating $650,000, so cancelled. Disallowance of the bad debt claims resulted in the deficiency complained of.
The findings of fact and opinion of the Tax Court are reported in 22 T.C. 1152. For present purposes an abbreviated statement will suffice. In…
2Cases cited9 opinions
- Commissioner v. JacobsonSupreme Court of the United States · 1949
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- Vincent C. Giblin v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1955
- Commissioner of Internal Revenue v. Auto Strop Safety Razor Co., Inc.Court of Appeals for the Second Circuit · 1934
- Carroll-McCreary Co. v. Commissioner of Internal Rev.Court of Appeals for the Second Circuit · 1941
4 more not listed; retrieve them via the Exa API.
3Cited by33 opinions
- Putoma Corp. v. CommissionerUnited States Tax Court · 1976
- Santa Anita Consol., Inc. v. CommissionerUnited States Tax Court · 1968
- Utilities & Industries Corp. v. CommissionerUnited States Tax Court · 1964
- Commissioner v. Fender Sales, Inc.Court of Appeals for the Ninth Circuit · 1964
- Edwin C. Hollenbeck and Kathryn J. Hollenbeck, Wade G. Ellis and Anita l.ellis v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1970
28 more not listed; retrieve them via the Exa API.