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 and 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