Pratt v. Commissioner
United States Board of Tax Appeals
Salaries credited to petitioners upon the books of the corporation of which they were officers and stockholders, but not received within the taxable years nor available for their use, were not income to them upon the cash receipts and disbursements basis.
1Opinion of the Court
*624OPINION.
Littleton:
The Commissioner held that the total amounts credited to petitioners as salary upon the books of the Elkhart Carriage & Motor Car Co. for each of the years 1919 and 1920 were actually or constructively received in each year and computed the tax accordingly. In these proceedings the petitioners conceded that the total of the items consisting of cash, Liberty bonds and merchandise, received in each of the years, should be taxed as salary, but they claim that the preferred stock and interest-bearing promissory notes of the Elkhart Carriage & Motor Car Co. and the common stock…
2Cited by2 opinions
- Pratt v. CommissionerUnited States Board of Tax Appeals · 1927
- St. Denis Sec. Co. v. CommissionerUnited States Tax Court · 1957