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Corporation v. Commr. of Internal Revenue

United States Court of Appeals, Second Circuit
Mar 28, 1957
242 F.2d 759 (2d Cir. 1957)

Opinion

No. 186, Docket 24359.

Argued March 5, 6, 1957.

Decided March 28, 1957.

Petition to review a decision of the Tax Court; Stephen E. Rice, Judge.

The Tax Court disallowed deductions claimed as interest paid on indebtedness under Internal Revenue Code of 1939, Section 23(b), 26 U.S.C.A. § 23(b), holding that advances made by stockholders to the taxpayer corporation were capital contributions rather than loans. T.C. Memo. 1956-174.

Bernard Weiss, New York City, for petitioner.

Charles K. Rice, Asst. Atty. Gen. (Lee A. Jackson and Morton K. Rothschild, Attorneys, Department of Justice, Washington, D.C.,), for respondent.

Before MEDINA and WATERMAN, Circuit Judges, and GALSTON, District Judge.


Affirmed on the findings of fact and opinion of Judge Rice, T.C.Memo. 1956-174.


Summaries of

Corporation v. Commr. of Internal Revenue

United States Court of Appeals, Second Circuit
Mar 28, 1957
242 F.2d 759 (2d Cir. 1957)
Case details for

Corporation v. Commr. of Internal Revenue

Case Details

Full title:241 CORPORATION, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE…

Court:United States Court of Appeals, Second Circuit

Date published: Mar 28, 1957

Citations

242 F.2d 759 (2d Cir. 1957)