PALM SPRINGS CORP. v. COMM'R.

No. 503.

315 U.S. 185 (1942)

PALM SPRINGS HOLDING CORPORATION v. COMMISSIONER OF INTERNAL REVENUE.

Supreme Court of United States.

Decided February 2, 1942.


Attorney(s) appearing for the Case

Mr. John E. Hughes, with whom Mr. Thomas R. Dempsey was on the brief, for petitioner.

Assistant Attorney General Clark, with whom Solicitor General Fahy, and Messrs. J. Louis Monarch and Samuel H. Levy were on the brief, for respondent.

Mr. Thomas J. Herbert, Attorney General of Ohio, filed a brief on behalf of that State, as amicus curiae, in support of petitioner.


MR. JUSTICE DOUGLAS delivered the opinion of the Court.

This case is a companion case to Helvering v. Alabama Asphaltic Limestone Co., ante, p. 179. This, too, was an insolvency reorganization, though a different procedure was employed to consummate it. The old corporation had outstanding about $300,000 face amount of first mortgage bonds, secured by a lien on its realty. The property, which was an hotel, was leased to an operating company. In 1931,...

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