Legal Opinion

Oregon-Washington Plywood Co. v. Commissioner

United States Tax Court

Decided July 10, 1953No. Docket No. 39553Published

Excess Profits Credit -- Borrowed Invested Capital. -- Held, that a land purchase contract and so-called note executed pursuant thereto were conditional and that the obligation under such instruments was not an outstanding indebtedness evidenced by either a note or a mortgage, within the meaning of section 719 (a) (1), Internal Revenue Code.

1Opinion of the Court

Oregon-Washington Plywood Company, an Oregon Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Oregon-Washington Plywood Co. v. Commissioner

Docket No. 39553

United States Tax Court

20 T.C. 816; 1953 U.S. Tax Ct. LEXIS 91;

July 10, 1953, Promulgated

Decision will be entered for the respondent.

Excess Profits Credit -- Borrowed Invested Capital. -- Held, that a land purchase contract and so-called note executed pursuant thereto were conditional and that the obligation under such instruments was not an outstanding indebtedness evidenced by either a note or a mortgage, within the…

2Cases cited11 opinions

  1. Journal Publishing Co. v. CommissionerUnited States Tax Court · 1944
  2. West Constr. Co. v. CommissionerUnited States Tax Court · 1946
  3. Flint Nortown Theatre Co. v. CommissionerUnited States Tax Court · 1945
  4. Bernard Realty Co. v. United StatesCourt of Appeals for the Seventh Circuit · 1951
  5. Consolidated Goldacres Co. v. CommissionerCourt of Appeals for the Tenth Circuit · 1947

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