Hearst Corp. v. Commissioner
United States Tax Court
Payment by subsidiary of interest on sums borrowed for benefit of parent, held on facts to be allowable deductions for purposes of personal holding company surtax as dividends paid if not as interest.
1Opinion of the Court
OPINION.
Opper, Judge:
A deficiency in personal holding company surtax of Hearst Estate, Inc., for 1941 in the amount of $15,718.97 has been determined against petitioner as transferee. The transferee liability is conceded and the questions are whether payments of interest made by petitioner’s transferor on money borrowed by it for the benefit of its parent are deductible either as such or as dividends; and whether, if not, the statute of limitations bars the collection of the deficiency. All of the facts have been stipulated and are hereby found accordingly.
The material portions of the…
2Cases cited5 opinions
- Palmer v. CommissionerSupreme Court of the United States · 1937
- Limericks, Inc. v. CommissionerUnited States Tax Court · 1946
- Young v. CommissionerUnited States Tax Court · 1945
- Strake Trust v. CommissionerUnited States Tax Court · 1943
- Rodney, Inc. v. CommissionerUnited States Tax Court · 1943
3Cited by11 opinions
- Chicago & N. W. R. Co. v. CommissionerUnited States Tax Court · 1958
- Collins Electrical Co. v. CommissionerUnited States Tax Court · 1977
- Schering Corp. v. CommissionerUnited States Tax Court · 1978
- Challenger, Inc. v. CommissionerUnited States Tax Court · 1964
- Chelsea Products, Inc. v. CommissionerUnited States Tax Court · 1951
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