Legal Opinion

Perlman v. Commissioner

United States Tax Court

Decided February 4, 1957No. Docket No. 58597Published

Petitioner was an officer and a substantial stockholder of an insurance company. The company's financial condition was precarious. In 1950 petitioner canceled the company's indebtedness to him for unpaid portions of his 1943-1947 salary. Held, the cancellation constituted a contribution to capital and was not deductible under section 23 (a) or (e), I. R. C. 1939.

1Opinion of the Court

Leo Perlman and Sima Perlman, Petitioners, v. Commissioner of Internal Revenue, Respondent

Perlman v. Commissioner

Docket No. 58597

United States Tax Court

27 T.C. 755; 1957 U.S. Tax Ct. LEXIS 268;

February 4, 1957, Filed

Decision will be entered for the respondent.

Petitioner was an officer and a substantial stockholder of an insurance company. The company's financial condition was precarious. In 1950 petitioner canceled the company's indebtedness to him for unpaid portions of his 1943-1947 salary. Held, the cancellation constituted a contribution to capital and was not deductible under section 23…

2Cases cited5 opinions

  1. Lidgerwood Manufacturing Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1956
  2. Sackstein v. CommissionerUnited States Tax Court · 1950
  3. O. D. Bratton v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1954
  4. Goldner v. CommissionerUnited States Tax Court · 1956
  5. Perlman v. CommissionerUnited States Tax Court · 1957

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