Anthony P. Miller, Inc. v. Commissioner
United States Tax Court
1. Petitioner, on January 1, 1941, delivered demand promissory notes to its president as compensation for services rendered during 1940. Held, such compensation was not "paid" within the meaning of section 24 (c) (1) of the Internal Revenue Code and is not deductible as a business expense by petitioner for 1940. 2. Determined that stock of X Co. did not become worthless in 1940. 3. Value of the stock of certain corporations paid petitioner for construction work determined.
1Opinion of the Court
Anthony P. Miller, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Anthony P. Miller, Inc. v. Commissioner
Docket No. 6666
United States Tax Court
7 T.C. 729; 1946 U.S. Tax Ct. LEXIS 81;
September 17, 1946, Promulgated
Decision will be entered under Rule 50.
1. Petitioner, on January 1, 1941, delivered demand promissory notes to its president as compensation for services rendered during 1940. Held, such compensation was not "paid" within the meaning of section 24 (c) (1) of the Internal Revenue Code and is not deductible as a business expense by petitioner for 1940.
2. Determined…
Also in this document: Dissent.
2Cases cited13 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Eckert v. BurnetSupreme Court of the United States · 1931
- Helvering v. City Bank Farmers Trust Co.Supreme Court of the United States · 1935
- Helvering v. PriceSupreme Court of the United States · 1940
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