Capitol Coal Corp. v. Commissioner
United States Tax Court
Held, cancellations of indebtedness by three of the taxpayer's creditors in the fiscal years ended May 31, 1942 and 1943, resulted in ordinary income in those years to the extent of the taxpayer's solvency after the cancellation, and the cancellation of indebtedness by a fourth creditor in the fiscal year 1942 was intended by such creditor as a gift; held, further, the tax benefit rule is not applicable under the facts of this case.
1Opinion of the Court
Capitol Coal Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
Capitol Coal Corp. v. Commissioner
Docket No. 51955
United States Tax Court
26 T.C. 1183; 1956 U.S. Tax Ct. LEXIS 78;
September 25, 1956, Filed
Decision will be entered under Rule 50.
Held, cancellations of indebtedness by three of the taxpayer's creditors in the fiscal years ended May 31, 1942 and 1943, resulted in ordinary income in those years to the extent of the taxpayer's solvency after the cancellation, and the cancellation of indebtedness by a fourth creditor in the fiscal year 1942 was intended by such…
2Cases cited18 opinions
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Commissioner v. JacobsonSupreme Court of the United States · 1949
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- Bowers v. Kerbaugh-Empire Co.Supreme Court of the United States · 1926
- Farr v. CommissionerUnited States Tax Court · 1948
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