HELVERING v. AMER. DENTAL CO.

No. 303.

318 U.S. 322 (1943)

HELVERING, COMMISSIONER OF INTERNAL REVENUE, v. AMERICAN DENTAL CO.

Supreme Court of United States.

Decided March 1, 1943.


Attorney(s) appearing for the Case

Mr. Samuel H. Levy, with whom Solicitor General Fahy, Assistant Attorney General Clark, and Messrs. Sewall Key and Newton K. Fox, and Miss Helen R. Carloss were on the brief, for petitioner.

Mr. John E. Hughes, with whom Mr. James A. O'Callaghan was on the brief, for respondent.


MR. JUSTICE REED delivered the opinion of the Court.

This writ of certiorari brings here for review the question of the taxability, as income, of rent and interest on accounts owed by the taxpayer which were cancelled by its creditors.

The taxpayer, a corporation, respondent here, owed certain past due bills for merchandise. This indebtedness was represented by interest-bearing notes. Interest upon these notes had been accrued for the years prior to 1937 and...

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