Legal Opinion
Scriptomatic, Inc. v. United States
District Court, E.D. Pennsylvania
Decided June 23, 1975No. Civ. A. 69-2791PublishedCited by 12 opinions
1Opinion of the Court
OPINION
DITTER, District Judge.
The question in this case is whether certain debentures which purported to evidence corporate indebtedness were, for federal income tax purposes, in reality shares of stock. Contending payments to debenture holders were interest, the corporation took deductions which were disallowed by Internal Revenue. The tax difference was then paid and this suit brought for its recovery. A jury having found against the taxpayer, appropriate motions for post trial relief are now before the court. I conclude that judgment for plaintiff, notwithstanding the verdict, must be…
2Cases cited24 opinions
- The Boeing Company v. Daniel C. ShipmanCourt of Appeals for the Fifth Circuit · 1969
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Tillman v. Wheaton-Haven Recreation Assn., Inc.Supreme Court of the United States · 1973
- Neville Chemical Company v. Union Carbide CorporationCourt of Appeals for the Third Circuit · 1970
- Fin Hay Realty Co. v. United StatesCourt of Appeals for the Third Circuit · 1968
19 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Temp-Way Corp. v. Continental BankDistrict Court, E.D. Pennsylvania · 1992
- Scriptomatic, Inc. v. United StatesCourt of Appeals for the Third Circuit · 1977
- United States v. State Street Bank & Trust Co.United States Bankruptcy Court, D. Delaware · 2014
- Fischer v. United StatesDistrict Court, E.D. Pennsylvania · 1977
- Long Island Lighting Co. v. Bokum Resources Corp.United States Bankruptcy Court, D. New Mexico · 1983
7 more not listed; retrieve them via the Exa API.