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LIDGERWOOD MFG. CO. v. COMMISSIONER OF INTERNAL REV.

No. 31, Docket 23533.

229 F.2d 241 (1956)

LIDGERWOOD MANUFACTURING CO., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided January 17, 1956.

Attorney(s) appearing for the Case

Francis E. H. Davies, for petitioner Fred R. Tansill and Goodwin, Rosenbaum, Meacham & White, Washington, D. C., of counsel.

H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, Hilbert P. Zarky and Frank E. A. Sander, Sp. Assts. to the Atty. Gen., for respondent.

Before SWAN, FRANK and LUMBARD, Circuit Judges.

SWAN, Circuit Judge.

The question presented by this appeal is whether the Tax Court erred in holding that the taxpayer's cancellation in 1946 of debts owed to it by two subsidiary corporations, whose stock was wholly owned by it, constituted capital contributions to the subsidiaries and precluded deduction as worthless debts of the amounts, aggregating $650,000, so cancelled. Disallowance of the bad debt claims resulted in...

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