Haskell & Barker Car Co. v. Commissioner
United States Board of Tax Appeals
(1) DEDUCTIONS. - Petitioner is entitled to deduct, in computing net income, the difference between the value of its own stock as stipulated between the parties, purchased in the open market for sale to employees, and the sale price thereof. (2) Petitioner is entitled to include in invested capital accounts receivable from employees on account of stock purchased, from date of acceptance of contract of purchase.
1Opinion of the Court
*1093OPINION.
MoRkis :
The first allegation of error is the failure of the respondent to allow as a deduction for the fiscal year ended January 31, 1919, an amount of $17.50 per share (difference between the stipulated market price of $42.50 and sale price to employees) on the stock which had not been paid for in full in the computation of net income. The respondent alleges and contends that there was no binding obligation upon the petitioner, certainly not more than contingent liability until the stock in question was fully paid for by the employee and his certificate of stock delivered to him.…
2Cases cited3 opinions
- Insurance Co. v. DutcherSupreme Court of the United States · 1877
- O'BRIEN v. MillerSupreme Court of the United States · 1897
- District of Columbia v. GallaherSupreme Court of the United States · 1888
3Cited by16 opinions
- Duncan Industries, Inc., etc. v. CommissionerUnited States Tax Court · 1979
- W. M. Ritter Lumber Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Commercial Inv. Trust Corp. v. CommissionerUnited States Board of Tax Appeals · 1933
- RJ Reynolds Tobacco Co. v. Commissioner of Int. Rev.Court of Appeals for the Fourth Circuit · 1938
- Package Machinery Co. v. CommissionerUnited States Board of Tax Appeals · 1933
11 more not listed; retrieve them via the Exa API.