Legal Opinion

Martell Builders, Inc. v. Commissioner

United States Tax Court

Decided September 23, 1964No. Docket Nos. 3700-62, 3701-62Unpublished

Held, respondent erred in disallowing to petitioner Martell, as an ordinary and necessary business expense, a substantial portion of loan fees paid to American Savings & Loan Association in connection with a subdivision development. Held, further, American is not liable as transferee of Martell.

1Opinion of the Court

Martell Builders, Inc., (a dissolved corporation) v. Commissioner. American Savings & Loan Association v. Commissioner.

Martell Builders, Inc. v. Commissioner

Docket Nos. 3700-62, 3701-62.

United States Tax Court

T.C. Memo 1964-250; 1964 Tax Ct. Memo LEXIS 90; 23 T.C.M. (CCH) 1501; T.C.M. (RIA) 64250;

September 23, 1964

Held, respondent erred in disallowing to petitioner Martell, as an ordinary and necessary business expense, a substantial portion of loan fees paid to American Savings & Loan Association in connection with a subdivision development. Held, further, American is not liable as…

2Cases cited3 opinions

  1. McEnaney v. CommissionerUnited States Tax Court · 1944
  2. Worth Steamship Corp. v. CommissionerUnited States Tax Court · 1946
  3. Monroe Sand & Gravel Co. v. CommissionerUnited States Board of Tax Appeals · 1937

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