Legal Opinion

United States Fidelity & Guaranty Co. v. Commissioner

United States Board of Tax Appeals

Decided December 5, 1939No. Docket No. 91398Published

A loan made by the Reconstruction Finance Corporation ostensibly to petitioner's subsidiary, but actually for petitioner's benefit in connection with which petitioner's preferred stock was delivered to the lender, held to justify deduction of payments to the Reconstruction Finance Corporation either as interest paid on petitioner's obligation or as dividends on stock held by an instrumentality of the United States. Revenue Act of 1934, secs. 23(b) and 121.

1Opinion of the Court

UNITED STATES FIDELITY AND GUARANTY COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Fidelity & Guaranty Co. v. Commissioner

Docket No. 91398.

United States Board of Tax Appeals

40 B.T.A. 1010; 1939 BTA LEXIS 766;

December 5, 1939, Promulgated

A loan made by the Reconstruction Finance Corporation ostensibly to petitioner's subsidiary, but actually for petitioner's benefit in connection with which petitioner's preferred stock was delivered to the lender, held to justify deduction of payments to the Reconstruction Finance Corporation either as interest paid on…

2Cases cited1 opinion

  1. United States Fidelity & Guaranty Co. v. CommissionerUnited States Board of Tax Appeals · 1939

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