New Process Cork Co. v. Commissioner
United States Board of Tax Appeals
1. In 1922 petitioner on the accrual basis entered upon its books as a closing entry of 1921 and paid an amount in settlement of a lawsuit against it for breach of contract begun in 1921. Held, the amount was not deductible for 1921. 2. An estimate entered in 1922 as of 1921 of attorneys' fees for services performed in 1921, which were not billed or paid until 1922, held not deductible for 1921.
1Opinion of the Court
*1341OPINION.
Steiínhagen:
The petitioner, relying upon Producers Fuel Co., 1 B. T. A. 202, and United States v. Anderson, 269 U. S. 422, urges the right to deduct in 1921 both the amount of its liability as ultimately agreed upon in 1922 and its estimate of its attorneys’ fees for the services rendered in respect of the suit. The controlling facts, it contends, are that the contract was broken by it in April, 1921, and that the amount of its liability was entered in its accounts before they were actually closed for 1921. The Commissioner, on the other hand, contends that, since the contract is not…
2Cases cited2 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
3Cited by7 opinions
- General Communication Co. v. CommissionerUnited States Tax Court · 1960
- Cannon Valley Milling Co. v. CommissionerUnited States Board of Tax Appeals · 1941
- General Communication Co. v. CommissionerUnited States Tax Court · 1960
- General Communication Co. v. CommissionerUnited States Tax Court · 1960
- Guy T. Gibson, Inc. v. CommissionerUnited States Board of Tax Appeals · 1942
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