Affiliated Capital Corp. v. Commissioner
United States Tax Court
In 1970, A incurred costs for the preparation and filing of a registration statement and prospectus with the Securities and Exchange Commission (SEC) for a public offering of 525,000 units of securities. Each unit consisted of 2 shares of common stock and one warrant for the purchase of a share of common stock at a stated or mathematically calculable price.
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In 1970, A incurred costs for the preparation and filing of a registration statement and prospectus with the Securities and Exchange Commission (SEC) for a public offering of 525,000 units of securities. Each unit consisted of 2 shares of common stock and one warrant for the purchase of a share of common stock at a stated or mathematically calculable price. In 1972 and 1975, A incurred additional costs for the preparation and filing with the SEC of post-effective amendments updating the registration statement and prospectus for the warrants. Held, A's costs in preparing and filing the…
1Opinion of the Court
FEATHERSTON, Judge:
Respondent determined a deficiency in the amount of $66,821 in petitioners’ Federal income tax for 1972. The deficiency arises from the partial disallowance of a claimed net operating loss carryback from 1975 to 1972 based on respondent’s determination that petitioners recognized gain in 1975 from the disposition or satisfaction of an installment obligation. Although recognition of such gain would not be sufficient to cause a deficiency for 1975, it would cause a decrease in the loss carryback. Petitioners here claim expense deductions for 1972 and 1975 which would further…
2Cases cited22 opinions
- Securities and Exchange Commission v. Manor Nursing Centers, Inc.Court of Appeals for the Second Circuit · 1972
- General Bancshares Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1964
- Davis v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1945
- Simmons Co. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1929
- Securities & Exchange Commission v. Bangor Punta Corp.District Court, S.D. New York · 1971
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3Cited by1 opinion
- Affiliated Capital Corp. v. CommissionerUnited States Tax Court · 1987