Legal Opinion

Lincoln Storage Warehouses v. Commissioner

United States Tax Court

Decided July 13, 1949No. Docket No. 18665Published

Petitioner corporation, on the accrual basis, credited the account of its sole stockholder, who was on the cash basis, with certain amounts for rents, salary, and interest over a period of years up to and including 1943 and part of 1944 and, after the stockholder's death in 1944, credited the account of the stockholder's estate, which respondent determined to be on the cash basis, with further items.

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Petitioner corporation, on the accrual basis, credited the account of its sole stockholder, who was on the cash basis, with certain amounts for rents, salary, and interest over a period of years up to and including 1943 and part of 1944 and, after the stockholder's death in 1944, credited the account of the stockholder's estate, which respondent determined to be on the cash basis, with further items. Petitioner made cash payments in 1943 to the stockholder and in 1944 to the stockholder and to his estate. There was no application either by petitioner or by the recipients of any of these…

1Opinion of the Court

Lincoln Storage Warehouses, Petitioner, v. Commissioner of Internal Revenue, Respondent

Lincoln Storage Warehouses v. Commissioner

Docket No. 18665

United States Tax Court

13 T.C. 33; 1949 U.S. Tax Ct. LEXIS 132;

July 13, 1949, Promulgated

Decision will be entered for the respondent.

Petitioner corporation, on the accrual basis, credited the account of its sole stockholder, who was on the cash basis, with certain amounts for rents, salary, and interest over a period of years up to and including 1943 and part of 1944 and, after the stockholder's death in 1944, credited the account of the…

Also in this document: Dissent.

2Cases cited8 opinions

  1. United States v. KirkpatrickSupreme Court of the United States · 1824
  2. Aluminum Castings Co. v. RoutzahnSupreme Court of the United States · 1930
  3. McConway & Torley Corp. v. CommissionerUnited States Tax Court · 1943
  4. Lincoln Storage Warehouses v. CommissionerUnited States Tax Court · 1949
  5. Long v. Republic Varnish Enamel & Lacquer Co.Supreme Court of New Jersey · 1934

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