Proctor Shop, Inc. v. Commissioner
United States Board of Tax Appeals
1. Petitioner issued so-called "debenture preference stock" which is determined to be evidence of indebtedness rather than stock, and the payments made thereon at the rate of 6 percent per annum are held to be deductible as interest paid. 2. The evidence establishes that amounts equal to 2 3/4 percent of gross sales allowed by respondent as additions to reserve for bad debts are insufficient to cover actual bad debts, and that additions equal to 4 percent of gross sales as…
Read the full summary
1. Petitioner issued so-called "debenture preference stock" which is determined to be evidence of indebtedness rather than stock, and the payments made thereon at the rate of 6 percent per annum are held to be deductible as interest paid. 2. The evidence establishes that amounts equal to 2 3/4 percent of gross sales allowed by respondent as additions to reserve for bad debts are insufficient to cover actual bad debts, and that additions equal to 4 percent of gross sales as claimed by petitioner represent reasonable additions to the reserve.
1Opinion of the Court
THE PROCTOR SHOP, INCORPORATED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Proctor Shop, Inc. v. Commissioner
Docket Nos. 58909, 66268.
United States Board of Tax Appeals
30 B.T.A. 721; 1934 BTA LEXIS 1278;
May 16, 1934, Promulgated
1. Petitioner issued so-called "debenture preference stock" which is determined to be evidence of indebtedness rather than stock, and the payments made thereon at the rate of 6 percent per annum are held to be deductible as interest paid.
2. The evidence establishes that amounts equal to 2 3/4 percent of gross sales allowed by respondent as additions to…
2Cases cited1 opinion
- Proctor Shop, Inc. v. CommissionerUnited States Board of Tax Appeals · 1934