Legal Opinion

George Hall Corp. v. Commissioner

United States Tax Court

Decided June 16, 1943No. Docket No. 107409PublishedCited by 14 opinions

Following Helvering v. American Dental Co., 318 U.S. 322, a voluntary cancellation of overdue interest on debentures held by a shareholder of the debtor is a gift and not taxable income to the debtor.

1Opinion of the Court

OPINION ON RECONSIDERATION.

Sternhagen, Judge:

This case is again before this Court on reconsideration because after the opinion of January 19, 1943, 1 T. C. 471, sustaining the deficiency, the Supreme Court on March 1,1943, handed down its decision in Helvering v. American Dental Co., 318 U. S. 322. The petitioner filed a motion for reconsideration in the light of that opinion and the Commissioner made no opposition. Supplemental memoranda have been filed.

We can see no escape from applying the same rationale to this case as was applied by the Supreme Court in the Dental case, requiring the…

2Cases cited2 opinions

  1. Helvering v. American Dental Co.Supreme Court of the United States · 1943
  2. George Hall Corp. v. CommissionerUnited States Tax Court · 1943

3Cited by14 opinions

  1. Putoma Corp. v. CommissionerUnited States Tax Court · 1976
  2. Putoma Corp., Successor by Merger of Pro-Mac Company, Petitioners- Cross-Appellants v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1979
  3. Pancoast Hotel Co. v. CommissionerUnited States Tax Court · 1943
  4. McConway & Torley Corp. v. CommissionerUnited States Tax Court · 1943
  5. Hartland Assoc. v. CommissionerUnited States Tax Court · 1970

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