Portland Mfg. Co. v. Commissioner
United States Tax Court
1. By December 1962, PMC had advanced a total of $ 2,987,000 to MFP which had been operating at a considerable loss for the prior 14 months. A mortgage on all MFP's assets in the amount of $ 1,800,000 had been given to PMC as partial security for the advances. A projection of income in November revealed that MFP could not possibly be operated at a profit under prevailing conditions, and MFP proceeded to wind up its affairs.
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1. By December 1962, PMC had advanced a total of $ 2,987,000 to MFP which had been operating at a considerable loss for the prior 14 months. A mortgage on all MFP's assets in the amount of $ 1,800,000 had been given to PMC as partial security for the advances. A projection of income in November revealed that MFP could not possibly be operated at a profit under prevailing conditions, and MFP proceeded to wind up its affairs. PMC, in December 1962, wrote down the debt of MFP in the amount of $ 2,365,000 which was the difference between the amount owed and the estimated salvage value of MFP's…
1Opinion of the Court
Stekrett, Judge:
Respondent has determined deficiencies in the income taxes of Portland Manufacturing Co. of $402,131 for the taxable year ended December 31,1959, and $569,040.75 for the taxable year ended December 31, 1962. It has also been determined by respondent that the petitioners Annabelle A. Houser; Duane Autzen; Thomas E. Autzen; Thomas Edward Autzen, Duane Autzen and United States National Bank of Oregon, Trustees U/W Thomas John Autzen, Deceased; Elizabeth J. Rossman; and the Autzen Foundation are liable for the above-stated deficiencies as transferees of Portland Manufacturing Co.
We…
2Cases cited28 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Griffiths v. CommissionerSupreme Court of the United States · 1939
- Minnesota Tea Co. v. HelveringSupreme Court of the United States · 1938
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
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3Cited by40 opinions
- Estate of Andrews v. CommissionerUnited States Tax Court · 1982
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- James and Martha Kuper and Charles and Kathleen Kuper, Cross-Appellees v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Fifth Circuit · 1976
- Associated Wholesale Grocers, Inc., and Its Subsidiary, Super Market Developers, Inc. v. United StatesCourt of Appeals for the Tenth Circuit · 1991
- Bank One Corp. v. Comm'rUnited States Tax Court · 2003
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