Brainard v. Commissioner
United States Tax Court
1. Interest payments owing by accrual basis taxpayer which were not likely to be paid because of petitioner's financial condition, held, on the facts, not allowable deductions, Zimmerman Steel Co., 45 B. T. A. 1041, notwithstanding that a different ground for the disallowance was specified by respondent in the statement attached to the notice of deficiency.
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1. Interest payments owing by accrual basis taxpayer which were not likely to be paid because of petitioner's financial condition, held, on the facts, not allowable deductions, Zimmerman Steel Co., 45 B. T. A. 1041, notwithstanding that a different ground for the disallowance was specified by respondent in the statement attached to the notice of deficiency. Edgar M. Carnrick, 21 B. T. A. 12, and Raoul H. Fleischmann, 40 B. T. A. 672, followed. 2. Dividends on pledged securities received by creditor, pursuant to dividend order, held, to be payment of interest, under applicable law, in the…
1Opinion of the Court
Millar Brainard and Katharine R. Brainard, Husband and Wife, Petitioners, v. Commissioner of Internal Revenue, Respondent
Brainard v. Commissioner
Docket No. 10158
United States Tax Court
7 T.C. 1180; 1946 U.S. Tax Ct. LEXIS 31;
November 21, 1946, Promulgated
Decision will be entered under Rule 50.
1. Interest payments owing by accrual basis taxpayer which were not likely to be paid because of petitioner's financial condition, held, on the facts, not allowable deductions, Zimmerman Steel Co., 45 B. T. A. 1041, notwithstanding that a different ground for the disallowance was specified by respondent…
2Cases cited4 opinions
- Pearlman v. CommissionerUnited States Tax Court · 1944
- Butler Consol. Coal Co. v. CommissionerUnited States Tax Court · 1946
- Bowen v. CommissionerUnited States Tax Court · 1943
- Brainard v. CommissionerUnited States Tax Court · 1946