Scope of Tax Benefit Rule Limited

Authors

Steven M. Harris
Ronald B. Ravikoff

Topic/Sub-heading

TAX

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.

Recommended Citation

Steven M. Harris & Ronald B. Ravikoff, Scope of Tax Benefit Rule Limited, 32 U. Mia. L. Rev. 487 (1978).
Available at: https://repository.law.miami.edu/umlr/vol32/iss2/11