Legal Opinion
Edward Katzinger Co. v. COMMISSIONER OF INT. REVENUE
Court of Appeals for the Seventh Circuit
Decided July 10, 1942No. 7854PublishedCited by 16 opinions
1Opinion of the Court
SPARKS, Circuit Judge.
The taxpayer petitions for review of a decision of the Board of Tax Appeals denying it a deduction for a bad debt loss resulting from a series of advances to a wholly owned subsidiary. The denial was based on the theory that allowance for the loss in 1936, the year of liquidation of the subsidiary, would permit a double deduction for the taxpayer who, the Commissioner alleged, had previously availed itself of the same loss by means of a consolidated return filed by the two corporations for the year 1933.
Petitioner is a corporation engaged in the business of manufacturing…
2Cases cited5 opinions
- Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
- McLaughlin v. Pacific Lumber Co.Supreme Court of the United States · 1934
- W. M. Ritter Lumber Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Greif Cooperage Corp. v. CommissionerCourt of Appeals for the Third Circuit · 1936
- Commissioner v. Emerson Carey Fibre Products Co.Court of Appeals for the Tenth Circuit · 1934
3Cited by16 opinions
- Rude v. CommissionerUnited States Tax Court · 1967
- Dittmar v. CommissionerUnited States Tax Court · 1955
- O'NEILL v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1948
- Malone & Hyde, Inc. v. CommissionerUnited States Tax Court · 1968
- Duquesne Light Holdings Inc v. Commissioner of Internal RevenCourt of Appeals for the Third Circuit · 2017
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