Reclaimed Island Lands Co. v. Commissioner
United States Board of Tax Appeals
Petitioner is a corporation the stock of which was held 40% by S, and the balance by members of S's family. Prior to 1936 it was indebted on its note in the sum of $424,000 to a trust company which also held reclamation district bonds which were a first lien on petitioner's property. Petitioner's note was secured by a deed of trust under which petitioner was prohibited from paying dividends so long as the note was outstanding.
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Petitioner is a corporation the stock of which was held 40% by S, and the balance by members of S's family. Prior to 1936 it was indebted on its note in the sum of $424,000 to a trust company which also held reclamation district bonds which were a first lien on petitioner's property. Petitioner's note was secured by a deed of trust under which petitioner was prohibited from paying dividends so long as the note was outstanding. Around January 1, 1936, the trust company agreed to rebate to petitioner a part of the interest called for by the note and bonds, in return for the personal guarantee…
1Opinion of the Court
RECLAIMED ISLAND LANDS CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Reclaimed Island Lands Co. v. Commissioner
Docket No. 104438.
United States Board of Tax Appeals
46 B.T.A. 1048; 1942 BTA LEXIS 782;
May 5, 1942, Promulgated
Petitioner is a corporation the stock of which was held 40% by S, and the balance by members of S's family. Prior to 1936 it was indebted on its note in the sum of $424,000 to a trust company which also held reclamation district bonds which were a first lien on petitioner's property. Petitioner's note was secured by a deed of trust under which petitioner…
2Cases cited7 opinions
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
- Meridian & T. Realty Co. v. CommissionerUnited States Board of Tax Appeals · 1941
- Lehigh Structural Steel Co. v. CommissionerUnited States Board of Tax Appeals · 1941
- Henry Mill & Timber Co. v. CommissionerUnited States Board of Tax Appeals · 1941
- Thibaut & Walker Co. v. CommissionerUnited States Board of Tax Appeals · 1940
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