Legal Opinion

Capitol Coal Corporation v. Commissioner of Internal Revenue

Court of Appeals for the Second Circuit

Decided December 6, 1957No. 24573_1PublishedCited by 21 opinions

1Opinion of the Court

MOORE, Circuit Judge.

The taxpayer, Capitol Coal Corporation, petitions for review of a decision of the Tax Court (26 T.C. 1183) finding deficiencies in income tax and declared value excess profits tax in the respective amounts of $13,100.27 and $3,958.96 for the fiscal year ended May 31, 1944.

The sole issue is the effect to be given to the cancellation of certain debts in May 1942 and March 1943 by four of the taxpayer’s business creditors. The government contends that these cancellations constitute taxable income. The taxpayer argues that the cancellation was not the result of an effort…

2Cases cited7 opinions

  1. Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
  2. Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
  3. Commissioner v. LoBueSupreme Court of the United States · 1956
  4. Commissioner v. JacobsonSupreme Court of the United States · 1949
  5. Eleanor A. Bradford v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956

2 more not listed; retrieve them via the Exa API.

3Cited by21 opinions

  1. Putoma Corp. v. CommissionerUnited States Tax Court · 1976
  2. Bialock v. CommissionerUnited States Tax Court · 1961
  3. Brutsche v. CommissionerUnited States Tax Court · 1976
  4. OKC Corp. v. CommissionerUnited States Tax Court · 1984
  5. Continental Illinois Nat'l Bank & Trust Co. v. CommissionerUnited States Tax Court · 1977

16 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API