Legal Opinion

Edmont Hotel Co. v. Commissioner

United States Tax Court

Decided February 10, 1948No. Docket No. 12327Published

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

  1. United States v. Kirby Lumber CoSupreme Court of the United States · 1931
  2. Helvering v. American Dental Co.Supreme Court of the United States · 1943
  3. Pancoast Hotel Co. v. CommissionerUnited States Tax Court · 1943
  4. Liberty Mirror Works v. CommissionerUnited States Tax Court · 1944
  5. Jacobson v. CommissionerUnited States Tax Court · 1946

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