[Download] "Roth Steel Tube Co. V. Commissioner Of Internal Revenue" by United States Court Of Appeals For The Sixth Circuit * eBook PDF Kindle ePub Free
eBook details
- Title: Roth Steel Tube Co. V. Commissioner Of Internal Revenue
- Author : United States Court Of Appeals For The Sixth Circuit
- Release Date : January 10, 1986
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 75 KB
Description
MILBURN, Circuit Judge. Roth Steel Tube Company ("taxpayer") appeals from a decision of the United States Tax Court sustaining deficiencies in the amount of $1,728,802 determined by the Commissioner of Internal Revenue ("the Commissioner") with respect to taxpayer's federal income tax liability for the taxable years 1971 through 1975. The principal issue presented is whether taxpayer's unrepaid advances to a subsidiary corporation were loans deductible as bad debts under 26 U.S.C. § 166 or capital contributions deductible only to the extent of capital gains under 26 U.S.C. § 1221. Because the Tax Court's factual determination that the advances were capital contributions and not loans is not clearly erroneous, we affirm.
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