Continental Illinois Nat'l Bank & Trust Co. v. Commissioner
United States Tax Court
In 1963 petitioner purchased an interest in conditional sales contracts and chattel mortgages guaranteed by corporations A, B, and C. During 1963, A, B, and C all filed petitions in bankruptcy under ch. XI, and petitioner filed claims therein with respect to the guarantees.
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In 1963 petitioner purchased an interest in conditional sales contracts and chattel mortgages guaranteed by corporations A, B, and C. During 1963, A, B, and C all filed petitions in bankruptcy under ch. XI, and petitioner filed claims therein with respect to the guarantees. Pursuant to the plan of arrangement, as confirmed, petitioner received in complete satisfaction of the contingent liability of A, B, and C, inter alia, two 10-year subordinated debentures of A and common stock of A. Petitioner nominally valued these assets at $ 1 each, writing off (after accounting for recoveries on the…
1Opinion of the Court
Continental Illinois National Bank & Trust Company of Chicago, Petitioner v. Commissioner of Internal Revenue, Respondent
Continental Illinois Nat'l Bank & Trust Co. v. Commissioner
Docket No. 4473-73
United States Tax Court
69 T.C. 357; 1977 U.S. Tax Ct. LEXIS 15;
December 5, 1977, Filed
Decision will be entered under Rule 155.
In 1963 petitioner purchased an interest in conditional sales contracts and chattel mortgages guaranteed by corporations A, B, and C. During 1963, A, B, and C all filed petitions in bankruptcy under ch. XI, and petitioner filed claims therein with respect to the guarantees.…
2Cases cited38 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
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