Edmont Hotel Co. v. Commissioner
United States Tax Court
The taxpayer, a solvent corporation, purchased its own bonds by direct negotiations with bondholders at a price equal to half of face value. Held: (1) The amount of discount on those acquired from a closely connected seller was a gratuitous forgiveness of debt, not taxable as income. (2) The amount of discount on one bond acquired from a seller not shown to have had personal or business relations with the taxpayer was taxable as income.
1Opinion of the Court
Edmont Hotel Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Edmont Hotel Co. v. Commissioner
Docket No. 12327
United States Tax Court
10 T.C. 260; 1948 U.S. Tax Ct. LEXIS 267;
February 10, 1948, Promulgated
Decision will be entered under Rule 50.
The taxpayer, a solvent corporation, purchased its own bonds by direct negotiations with bondholders at a price equal to half of face value. Held:(1) The amount of discount on those acquired from a closely connected seller was a gratuitous forgiveness of debt, not taxable as income.(2) The amount of discount on one bond acquired from a…
Also in this document: Concurrence.
2Cases cited7 opinions
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- Pancoast Hotel Co. v. CommissionerUnited States Tax Court · 1943
- Liberty Mirror Works v. CommissionerUnited States Tax Court · 1944
- Jacobson v. CommissionerUnited States Tax Court · 1946
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