Leach Corp. v. Commissioner
United States Tax Court
1. Held, that notwithstanding a high debt-to-capital ratio in respect of taxpayer corporation's financial structure, the indebtedness, when considered in the light of all the evidence, was bona fide, and interest with respect thereto is deductible. 2. Held, certain expenses were incurred in connection with issuance of bonds and may therefore be amortized over the life of the bonds.
1Opinion of the Court
The respondent determined the following deficiencies in income tax of petitioner:
Tamable year Amount
Apr. 22 1949 to Feb. 28,1950_$7,719.94
Fiscal year ended Feb. 28, 1951_ 9,666. 70
Fiscal year ended Feb. 29,1952_ 85, 634. 39
The petitioner contends that it overpaid its tax for each of the periods listed above and that it is entitled to a refund.
The parties have entered into stipulations relating to issues involving the amount of depreciation allowable for each year, and also the amount of capital gain or loss on machinery and equipment sold during the year ended February 29, 1952. These issues…
2Cases cited7 opinions
- Helvering v. Union Pacific RailroadSupreme Court of the United States · 1934
- Colony, Inc. v. CommissionerUnited States Tax Court · 1956
- Beckwith v. SheldonCalifornia Supreme Court · 1914
- Higgins v. MansonCalifornia Supreme Court · 1899
- Haas v. RendlemanCourt of Appeals for the Fourth Circuit · 1933
2 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- Estate of Travis Mixon, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
- American Processing and Sales Company v. The United StatesUnited States Court of Claims · 1967
- Ambassador Apartments, Inc. v. CommissionerUnited States Tax Court · 1968
- 2554-58 Creston Corp. v. CommissionerUnited States Tax Court · 1963
- State of Washington v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1982
23 more not listed; retrieve them via the Exa API.