Arcade Realty Co. v. Commissioner
United States Tax Court
1. Petitioner, a corporation engaged in the real estate business, in January 1951 obtained a loan of $ 15,559 from Jefferson Loan Company (completely owned by petitioner's stockholders), secured by a second mortgage on an office building. Later, in July 1951, petitioner obtained another loan from Jefferson in the amount of $ 15,663.29 secured by a third mortgage on the building. Said funds were deposited to petitioner's bank account.
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1. Petitioner, a corporation engaged in the real estate business, in January 1951 obtained a loan of $ 15,559 from Jefferson Loan Company (completely owned by petitioner's stockholders), secured by a second mortgage on an office building. Later, in July 1951, petitioner obtained another loan from Jefferson in the amount of $ 15,663.29 secured by a third mortgage on the building. Said funds were deposited to petitioner's bank account. The third mortgage loan was recorded on petitioner's books as an account receivable in the personal account of Joseph Mitchell, who, together with his wife, and…
1Opinion of the Court
FisheR, Judge:
Respondent determined deficiencies in income tax and additions to the tax under section 291(a) of the 1939 Code1 as follows:
Addition Year Income taw see. 291(a)
1951_ $2, 808. 85 $702.21
1952_ 1, 986.19 297.93
4,795. 04 1, 000.14
At the trial petitioner conceded issues raised in its petition relating to: (1) Management and collection expenses claimed for the years 1951 and 1952; (2) additional depreciation claimed on rental property for the years 1951 and 1952; and (3) additional repair expenses claimed for the year 1952.
The remaining issues presented are: (1) Whether interest paid…
2Cases cited23 opinions
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
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