WALLACE

v.

FRANZ

Citator

Cited By

• H. Liebes & Co. v. Commissioner of Internal Revenue, 90 F.2d 932 (9th Cir. 1937)
  …A.2) 72 F.(2d) 265, 267; Commissioner v. Brooklyn R. S. Corp. (C.C.A.2) 79 F.(2d) 833, 834; 1 Paul & Mertens, Law of Federal Income Taxation, 557, § 11.73. See, also, American Cigar Co. v. Commissioner (C.C.A.2) 66 F.(2d) 425, 426, certiorari denied 290 U.S. 699, 54 S.Ct. 209, 78 L.Ed. 601; Helvering v. Russian [*938] Finance & Construction Corp. (C.C.A.2) 77 F. (2d) 324, 327. • The complete definition would therefore seem to be that income accrues to a taxpayer, when there arises to him a fixed or uncondi…
• Maloney v. Spencer, 172 F.2d 638 (9th Cir. 1949)
  …he liabilities were agreed to be incurred by taxpayer in the expectancy that the corporations would be successful in business and pay off the obligations to him, unlike American Cigar Co. v. Commissioner, 2 Cir., 66 F. 2d 425, 427, certiorari denied 290 U.S. 699, 54 S.Ct. 209, 78 L.Ed. 601, where the taxpayer took notes of the corporation of which he was a stockholder for advances to it, fully believing they were worthless and uncollectible. The judgment is affirmed.…
• W. F. Young, Inc. v. Commissioner of Internal Revenue, 120 F.2d 159 (1st Cir. 1941)
  …pectation of repayment. Such advances, made with the belief that they would not be repaid, are in the nature of gifts, and are not deductible as bad debts. American Cigar Co. v. Commissioner, 2 Cir., 1933, 66 F. 2d 425, 427, certiorari denied, 1933, 290 U.S. 699, 54 S.Ct. 209, 78 L.Ed. 601; C. B. Hayes v. Commissioner of Internal Revenue, 1929, 17 B.T.A. 86; see Shiman v. Commissioner, 2 Cir., 1932, 60 F. 2d 65, 66; cf. Kinkead v. Commissioner, 3 Cir., 1934, 71 F. 2d 522; Redfield v. Eaton, D. C.Conn.1931,…