American Credit Corp. v. Commissioner
United States Tax Court
Held, certain debts acquired by petitioner on March 31, 1962, in a Type C reorganization under sec. 368(a) (1) (C) 1Unless otherwise noted, all statutory references are to the 1954 Internal Revenue Code, as amended. were not wholly worthless, but only partially worthless when acquired.
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Held, certain debts acquired by petitioner on March 31, 1962, in a Type C reorganization under sec. 368(a) (1) (C) 1Unless otherwise noted, all statutory references are to the 1954 Internal Revenue Code, as amended. were not wholly worthless, but only partially worthless when acquired. Petitioner acquired the transferor's basis in the debts under sec. 362(b) and properly deducted the unrecovered amounts of indebtedness under sec. 166 in its taxable years ending August 31, 1962, and 1963. Held, further, certain stock acquired in the above reorganization became completely worthless at some time…
1Opinion of the Court
AMERICAN CREDIT CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
American Credit Corp. v. Commissioner
Docket No. 5339-67.
United States Tax Court
T.C. Memo 1973-33; 1973 Tax Ct. Memo LEXIS 251; 32 T.C.M. (CCH) 122; T.C.M. (RIA) 73033;
February 13, 1973, Filed
Held, certain debts acquired by petitioner on March 31, 1962, in a Type C reorganization under sec. 368(a) (1) (C) 1 were not wholly worthless, but only partially worthless when acquired. Petitioner acquired the transferor's basis in the debts under sec. 362(b) and properly deducted the unrecovered amounts of…
2Cases cited10 opinions
- Eckert v. BurnetSupreme Court of the United States · 1931
- Seaboard Commercial Corp. v. CommissionerUnited States Tax Court · 1957
- Bihlmaier v. CommissionerUnited States Tax Court · 1951
- Los Angeles Shipbuilding & Drydock Corporation v. United States of America, United States of America v. Los Angeles Shipbuilding & Drydock CorporationCourt of Appeals for the Ninth Circuit · 1961
- Hoyt v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1944
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3Cited by1 opinion
- Rockland Credit v. Fenestration Architec.Superior Court of Rhode Island · 2008