Baltimore Steam Packet Co. v. Commissioner
United States Board of Tax Appeals
In 1935 petitioner was indebted to 3 banks and it executed a written agreement with them that, effective January 1, 1936, any net income, as "net income" is defined by accounting regulations of the Interstate Commerce Commission, accruing during the life of the loans, should be applied pro rata in reduction of the loans. Petitioner's net income for 1936 was $25,490.23 and all of this was paid to the 3 banks.
Read the full summary
In 1935 petitioner was indebted to 3 banks and it executed a written agreement with them that, effective January 1, 1936, any net income, as "net income" is defined by accounting regulations of the Interstate Commerce Commission, accruing during the life of the loans, should be applied pro rata in reduction of the loans. Petitioner's net income for 1936 was $25,490.23 and all of this was paid to the 3 banks. Held, (1) that, for purposes of section 26(c)(2) of the Revenue Act of 1936, the contractual provision requiring all of petitioner's "net income" to be applied to the loans was a…
1Opinion of the Court
BALTIMORE STEAM PACKET COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Baltimore Steam Packet Co. v. Commissioner
Docket No. 102559.
United States Board of Tax Appeals
44 B.T.A. 629; 1941 BTA LEXIS 1293;
June 5, 1941, Promulgated
In 1935 petitioner was indebted to 3 banks and it executed a written agreement with them that, effective January 1, 1936, any net income, as "net income" is defined by accounting regulations of the Interstate Commerce Commission, accruing during the life of the loans, should be applied pro rata in reduction of the loans. Petitioner's net income for…
2Cases cited2 opinions
- Michigan Silica Co. v. CommissionerUnited States Board of Tax Appeals · 1940
- Baltimore Steam Packet Co. v. CommissionerUnited States Board of Tax Appeals · 1941