Legal Opinion

John W. Walter, Inc. v. Commissioner

United States Tax Court

Decided December 30, 1954No. Docket No. 44002Published

1. On facts, issuance of petitioner's debentures held to have been supported by consideration rendering them valid corporate obligations. 2. Interest on debentures, designated as such, payable in 10 years with fixed interest rate of 3 1/2 per cent and no accompanying rights of management, issued by petitioner corporation in exchange for valuable property without excessive relation to equity investment held, further, deductible as interest on indebtedness.

1Opinion of the Court

John W. Walter, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

John W. Walter, Inc. v. Commissioner

Docket No. 44002

United States Tax Court

23 T.C. 550; 1954 U.S. Tax Ct. LEXIS 9;

December 30, 1954, Filed

Decision will be entered for the petitioner.

1. On facts, issuance of petitioner's debentures held to have been supported by consideration rendering them valid corporate obligations.

2. Interest on debentures, designated as such, payable in 10 years with fixed interest rate of 3 1/2 per cent and no accompanying rights of management, issued by petitioner corporation in exchange…

2Cases cited9 opinions

  1. Bazley v. CommissionerSupreme Court of the United States · 1947
  2. Commissioner of Internal Revenue v. OPP Holding Corp.Court of Appeals for the Second Circuit · 1935
  3. 1432 Broadway Corp. v. Commissioner of Internal Rev.Court of Appeals for the Second Circuit · 1947
  4. Mullin Bldg. Corp. v. CommissionerUnited States Tax Court · 1947
  5. Thompson v. Commissioner of Internal Revenue. Couse v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953

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