Legal Opinion
American-La France-Foamite Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided December 13, 1960No. 9, Docket 26030PublishedCited by 21 opinions
1Opinion of the Court
MOORE, Circuit Judge.
By petition for review, petitioner, American-La France-Foamite Corporation, seeks to reverse so much of a decision of the Tax Court as denied petitioner a deduction of $506,887.06 in its 1951 income tax included in its return as a worthless debt. As a result of this dis- allowance, a deficiency in income tax of $266,558.13 was assessed.
The sole question presented is whether advances made during the years 1947 1 to 1951 by petitioner to International Meters, Inc. (IMI) represented capital contributions or loans. If they were loans, they were deductible in 1951, the year of…
2Cases cited9 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- John v. Rowan v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Benjamin D. And Madeline Prentice Gilbert, on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Second Circuit · 1959
4 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Diamond Bros. Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1963
- Road Materials, Inc. v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Road Materials, Inc.Court of Appeals for the Fourth Circuit · 1969
- Walter I. Dodd and Amelia Lee Dodd v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1962
- Hambuechen v. CommissionerUnited States Tax Court · 1964
- Comtel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
16 more not listed; retrieve them via the Exa API.