Legal Opinion

Petit Anse Co. v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided May 9, 1946No. 11427PublishedCited by 3 opinions

1Opinion of the Court

WALLER, Circuit Judge.

Two questions are involved in this case: (1) whether or not payments of eight per cent, if and when earned and declared, as provided for in certain “8 percent Registered Non-Cumulative Fifty Year Gold Debentures” were payments of interest on an indebtedness within the meaning of the statutes allowing deduction of same from gross income, or were merely distributions of earnings of the corporation in the nature of dividends; and (2) when a discovery is made in the operation and development of a salt mine that there is a larger number of remaining salt units than had been…

2Cases cited4 opinions

  1. Dobson v. CommissionerSupreme Court of the United States · 1944
  2. McCahill v. HelveringCourt of Appeals for the Eighth Circuit · 1935
  3. Kehota Mining Co. v. LewellynDistrict Court, W.D. Pennsylvania · 1928
  4. Kehota Mining Co. v. LewellynCourt of Appeals for the Third Circuit · 1929

3Cited by3 opinions

  1. Ah Pah Redwood Company, a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957
  2. Ah Pah Redwood Co. v. CommissionerUnited States Tax Court · 1956
  3. Ah Pah Redwood Co. v. CommissionerUnited States Tax Court · 1956

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