Legal Opinion
Diamond Bros. Company v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided September 24, 1963No. 14280PublishedCited by 50 opinions
1Opinion of the Court
GANEY, Circuit Judge.
The question posed on this petition for review is whether advances by petitioner to Park Lane Furniture Mfg., Inc., (a corporation in which petitioner was a 50%- stockholder) from October of 1953 through December of 1954 were loans- or capital contributions. The Tax Court 1 found that the advances were contributions to capital, and sustained the Commissioner of Internal Revenue’s determination of income tax deficiency, based on his disallowance of petitioner’s claim in its income tax return that $100,079.75 of the advances was a bad-debt deduction in its fiscal year…
2Cases cited22 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Boehm v. CommissionerSupreme Court of the United States · 1945
- White v. United StatesSupreme Court of the United States · 1938
- Benjamin D. And Madeline Prentice Gilbert, on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Second Circuit · 1959
17 more not listed; retrieve them via the Exa API.
3Cited by50 opinions
- Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
- Estate of Travis Mixon, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
- United States v. Felix Benitez RexachCourt of Appeals for the First Circuit · 1973
- Dixie Dairies Corp. v. CommissionerUnited States Tax Court · 1980
- Segel v. CommissionerUnited States Tax Court · 1987
45 more not listed; retrieve them via the Exa API.