Legal Opinion

American Cigar Co. v. Commissioner

United States Board of Tax Appeals

Decided November 29, 1930No. Docket No. 16229Published

1. The amount of earned surplus for the years 1918 to 1920 which resulted from a profitable transaction of 1902 determined. 2. The petitioner advanced money to a debtor corporation with which that corporation paid interest on its bonds to the petitioner and others who owned the bonds.

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1. The amount of earned surplus for the years 1918 to 1920 which resulted from a profitable transaction of 1902 determined. 2. The petitioner advanced money to a debtor corporation with which that corporation paid interest on its bonds to the petitioner and others who owned the bonds. Held that the Commissioner did not err in including the amount of the interest due on the bonds owned by the petitioner in the petitioner's gross income, and, further, that the amount of this interest should not be deducted as debts ascertained to be worthless and charged off. 3. Where, at the time an interest…

1Opinion of the Court

AMERICAN CIGAR CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

American Cigar Co. v. Commissioner

Docket No. 16229.

United States Board of Tax Appeals

21 B.T.A. 464; 1930 BTA LEXIS 1842;

November 29, 1930, Promulgated

1. The amount of earned surplus for the years 1918 to 1920 which resulted from a profitable transaction of 1902 determined.

2. The petitioner advanced money to a debtor corporation with which that corporation paid interest on its bonds to the petitioner and others who owned the bonds. Held that the Commissioner did not err in including the amount of the interest due…

2Cases cited28 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. LaBelle Iron Works v. United StatesSupreme Court of the United States · 1921
  3. Lucas v. Kansas City Structural Steel Co.Supreme Court of the United States · 1930
  4. Willcuts v. Milton Dairy Co.Supreme Court of the United States · 1927
  5. Great Northern Railway Co. v. CommissionerUnited States Board of Tax Appeals · 1927

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