Scope of Tax Benefit Rule Limited

Harris, Steven M. & Ravikoff, Ronald B.

Journal: University of Miami Law Review

Volume: 32

First Page: 487

Year: 1978

Bluebook Citation: 32 U. MIAMI L. REV. 487 (1978)

Author: Steven M. Harris: all 1 publication


Abstract

In Putoma Corp. the Tax Court decided that foregiveness of interest indebtedness owed by a corporation (which had deducted for the accrued but unpaid interest) to a shareholder did not result in taxable income to the corporation because the interest foregiveness was a contribution to capital. The authors dispute the court's analysis and suggest a framework for future decisions concerning this problem.

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