Hyplains Dressed Beef, Inc. v. Commissioner
United States Tax Court
Petitioner accrued officers' salaries but did not in actuality pay them within 2 1/2 months after the close of the taxable year. Held, sec. 267(a)(2), I.R.C. 1954, inapplicable; the amounts were constructively received by those entitled to them.
1Opinion of the Court
Tietjens, Judge;
The Commissioner determined deficiencies in petitioner’s Federal income tax for taxable years 1964 and 1965 in the respective amounts of $40,321.48 and $13,704. The sole issue confronting us is whether officers’ salaries of $55,650 and $27,300, accrued for 1964 and 1965 respectively, are prohibited from being deducted by section 267,1.R.C. 1954.1
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation and exhibits attached thereto are incorporated herein by this reference. HyPlains Dressed Beef, Inc., sometimes hereinafter referred to as petitioner, is a…
2Cases cited9 opinions
- Geiger & Peters, Inc. v. CommissionerUnited States Tax Court · 1957
- Silverman v. CommissionerUnited States Tax Court · 1957
- Ohio Battery & Ignition Co. v. CommissionerUnited States Tax Court · 1945
- Platt Trailer Co. v. CommissionerUnited States Tax Court · 1955
- Akron Welding & Spring Co. v. CommissionerUnited States Tax Court · 1948
4 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Fountain v. CommissionerUnited States Tax Court · 1973
- Jerome Castree Interiors, Inc. v. CommissionerUnited States Tax Court · 1975
- Gillis v. CommissionerUnited States Tax Court · 1974
- Lacy Contracting Co. v. CommissionerUnited States Tax Court · 1971
- Vern Realty, Inc. v. CommissionerUnited States Tax Court · 1972
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