Legal Opinion

Gussow, Kahn & Co. v. Commissioner

United States Tax Court

Decided October 19, 1949No. Docket No. 16970Published

Petitioner during 1943 and 1944 advanced to its wholly owned subsidiary a total of $ 11,334.43. These advances constituted the only capital of the subsidiary during the year involved and they represented an investment by petitioner in the unissued capital stock of the subsidiary.

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Petitioner during 1943 and 1944 advanced to its wholly owned subsidiary a total of $ 11,334.43. These advances constituted the only capital of the subsidiary during the year involved and they represented an investment by petitioner in the unissued capital stock of the subsidiary. This investment became worthless during the taxable year when it was determined to liquidate the subsidiary, and it is therefore held that, with the exception of the advances made after the determination to liquidate the subsidiary, petitioner may deduct the advances involved under section 23 (g) (4) of the Internal…

1Opinion of the Court

Gussow, Kahn & Co., Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Gussow, Kahn & Co. v. Commissioner

Docket No. 16970

United States Tax Court

13 T.C. 580; 1949 U.S. Tax Ct. LEXIS 61;

October 19, 1949, Promulgated

Decision will be entered under Rule 50.

Petitioner during 1943 and 1944 advanced to its wholly owned subsidiary a total of $ 11,334.43. These advances constituted the only capital of the subsidiary during the year involved and they represented an investment by petitioner in the unissued capital stock of the subsidiary. This investment became worthless during the taxable…

Also in this document: Dissent.

2Cases cited3 opinions

  1. Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
  2. Janeway v. CommissionerUnited States Tax Court · 1943
  3. Gussow, Kahn & Co. v. CommissionerUnited States Tax Court · 1949

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