Legal Opinion
1432 Broadway Corp. v. Commissioner of Internal Rev.
Court of Appeals for the Second Circuit
Decided March 27, 1947No. 20, Docket 20234PublishedCited by 58 opinions
1Per curiam
The facts are stated in the opinion of the Tax Court, 4 T.C. 1158, and need not be here repeated. The issue presented was whether the taxpayer was entitled under section 23(b) of the Internal Revenue Code, 26 U.S.C.A. Int.Rev.Code, § 23(b), to deduct interest accrued within the taxable years on its outstanding debentures. The Tax Court denied deduction on the ground that the evidence did not show that “the debentures were, or were intended ta be, evidences of indebtedness”; they were “more nearly like preferred stock than indebtedness.” These conclusions are not within the scope of our…
2Cases cited2 opinions
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Elliott-Lewis Co. v. CommissionerCourt of Appeals for the Third Circuit · 1946
3Cited by58 opinions
- Benjamin D. And Madeline Prentice Gilbert, on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Second Circuit · 1959
- Kraft Foods Company v. Commissioner of Internal Revenue, (Two Cases)Court of Appeals for the Second Circuit · 1956
- Zivnuska v. CommissionerUnited States Tax Court · 1959
- Burr Oaks Corp. v. CommissionerUnited States Tax Court · 1965
- Earle, Collector of Internal Revenue v. W. J. Jones & Son, Inc. United States v. W. J. Jones & Son, IncCourt of Appeals for the Ninth Circuit · 1952
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