Marsh v. Commissioner
United States Tax Court
On or before October 14, 1943, petitioners and their associates had loaned $ 65,000 to the United Tube Corporation in consideration of the corporation's promissory notes and 6,500 shares of new no par common stock, when authorized to be issued dated October 14, 1943. The stock certificates were issued February 26, 1944, after formal amendment of the corporate charter in February, and they were dated October 14, 1943. On May 23, 1944, petitioners sold their stock in the…
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On or before October 14, 1943, petitioners and their associates had loaned $ 65,000 to the United Tube Corporation in consideration of the corporation's promissory notes and 6,500 shares of new no par common stock, when authorized to be issued dated October 14, 1943. The stock certificates were issued February 26, 1944, after formal amendment of the corporate charter in February, and they were dated October 14, 1943. On May 23, 1944, petitioners sold their stock in the United Tube Corporation. Held, that petitioners and their associates acquired a beneficial interest in the 6,500 shares of…
1Opinion of the Court
OPINION.
Black, Judge:
In these consolidated proceedings the Commissioner determined deficiencies in the income taxes of the petitioners for the calendar years 1943 and 1944, as follows:
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The deficiencies are due to several adjustments in petitioners’ net incomes as disclosed by the returns for the years involved. By appropriate assignments of error petitioners contest these adjustments. Petitioners have either abandoned, conceded, or stipulated to an adjustment of all but one of the issues involved. This leaves for our consideration the contested adjustment for the year 1944; i.…
2Cases cited4 opinions
- Brewster v. GageSupreme Court of the United States · 1930
- Richardson v. ShawSupreme Court of the United States · 1908
- McFeely v. CommissionerSupreme Court of the United States · 1935
- Fordyce v. HelveringCourt of Appeals for the D.C. Circuit · 1935
3Cited by24 opinions
- Morgan v. CommissionerUnited States Tax Court · 1966
- Scientific Instrument Co. v. CommissionerUnited States Tax Court · 1952
- George W. S. Swenson and Ruth E. Swenson v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1962
- Henry H. Bonsall, Jr., and Martha G. Bonsall, C. Jordan Vail and Nancy B. Vail v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1963
- Carpenter v. CommissionerUnited States Tax Court · 1953
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