Central Foundry Co. v. Commissioner
United States Tax Court
In a proxy contest between management and a group of insurgent stockholders, the latter prevailed and obtained a majority of seats on petitioner's board of directors. Thereafter, petitioner's stockholders approved the payment of the ousted management's proxy-solicitation expenses as well as those of the insurgents (now the new management) incurred in 1959. The Commissioner has conceded, after originally disallowing, the deductibility of the ousted management's expenses.
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In a proxy contest between management and a group of insurgent stockholders, the latter prevailed and obtained a majority of seats on petitioner's board of directors. Thereafter, petitioner's stockholders approved the payment of the ousted management's proxy-solicitation expenses as well as those of the insurgents (now the new management) incurred in 1959. The Commissioner has conceded, after originally disallowing, the deductibility of the ousted management's expenses. Held, on this record, the payment of the insurgents' expenses was no less proximately related to petitioner's business than…
1Opinion of the Court
Central Foundry Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Central Foundry Co. v. Commissioner
Docket No. 946-65
United States Tax Court
49 T.C. 234; 1967 U.S. Tax Ct. LEXIS 6;
December 18, 1967, Filed
Decision will be entered under Rule 50.
In a proxy contest between management and a group of insurgent stockholders, the latter prevailed and obtained a majority of seats on petitioner's board of directors. Thereafter, petitioner's stockholders approved the payment of the ousted management's proxy-solicitation expenses as well as those of the insurgents (now the new…
Also in this document: Dissent.
2Cases cited19 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Commissioner v. WilcoxSupreme Court of the United States · 1946
- Challenge Mfg. Co. v. CommissionerUnited States Tax Court · 1962
- Blackmer v. CommissionerCourt of Appeals for the Second Circuit · 1934
- Alleghany Corp. v. CommissionerUnited States Tax Court · 1957
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