George Hall Corp. v. Commissioner
United States Tax Court
The amount forgiven by a shareholder of interest in arrears on debentures of the corporation held by him, which interest, in common with all the other interest on the debentures, had been deducted by the corporation on its returns for the years when it accrued, is properly included within the corporation's income in the year of forgiveness.
1Opinion of the Court
OPINION.
Sternhagen, Judge:
The question at issue is whether the amount forgiven by a shareholder of an indebtedness of his corporation to him for arrears of interest on debentures held by him is properly included in the corporation’s income in the year of the forgiveness. The interest, in common with all the other interest on the debentures, had been deducted by the corporation on its returns for the years when the interest accrued. The Commissioner held that the amount constitutes taxable income and the corporation contests the holding. The principal ground for the petitioner’s conclusion is…
2Cases cited2 opinions
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Pondfield Realty Co. v. CommissionerUnited States Tax Court · 1942
3Cited by3 opinions
- Pancoast Hotel Co. v. CommissionerUnited States Tax Court · 1943
- George Hall Corp. v. CommissionerUnited States Tax Court · 1943
- George Hall Corp. v. CommissionerUnited States Tax Court · 1943