Legal Opinion
Simmons Co. v. Commissioner of Internal Revenue
Court of Appeals for the First Circuit
Decided May 31, 1929No. 2322PublishedCited by 33 opinions
1Opinion of the Court
ANDERSON, Circuit Judge.
On December 15, 1924, the Commissioner of Internal Revenue notified the petitioner of deficiencies in its income and profits taxes for 1919 of $222,319.71, and for 1920 of $61,327.-77. On appeal to the Board of -Tax Appeals, the deficiencies for 1919 and 1920 were redetermined as $188,383.20 and $29,298.62, respectively. On appeal to this court, the main contentions are: That commissions paid by the taxpayer on the sale of its own capital stock are, under section 234(a) (1) of the Revenue Act of 1918, ehap. 18, 40 Stat. 1057, 1077, “deductible as ordinary and necessary…
2Cases cited6 opinions
- LaBelle Iron Works v. United StatesSupreme Court of the United States · 1921
- National Lead Co. v. United StatesSupreme Court of the United States · 1920
- Willcuts v. Milton Dairy Co.Supreme Court of the United States · 1927
- Baltzell v. MitchellCourt of Appeals for the First Circuit · 1925
- Brewster v. GageCourt of Appeals for the Second Circuit · 1929
1 more not listed; retrieve them via the Exa API.
3Cited by33 opinions
- Estate of Thomas v. CommissionerUnited States Tax Court · 1985
- General Bancshares Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1964
- Fort Howard Corp. v. CommissionerUnited States Tax Court · 1994
- Baltimore & OR Co. v. Commissioner of Internal Rev.Court of Appeals for the Fourth Circuit · 1935
- Bard-Parker Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1955
28 more not listed; retrieve them via the Exa API.