San Carlos Milling Co. v. Commissioner
United States Board of Tax Appeals
1. Petitioner operated a sugar mill in the Philippine Islands under contracts with planters of sugar cane, whereby it milled the cane produced by the planters, and accepted as compensation for its milling services a percentage of the manufactured sugar.
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1. Petitioner operated a sugar mill in the Philippine Islands under contracts with planters of sugar cane, whereby it milled the cane produced by the planters, and accepted as compensation for its milling services a percentage of the manufactured sugar. Held, the sugar so received constituted income at the time and place received to the extent of its fair market value. 2. For the three-year period ended at the close of the taxable year 1923, petitioner received more than 80 per cent of its gross income from sources within a possession of the United States, and more than 50 per cent of its…
1Opinion of the Court
SAN CARLOS MILLING COMPANY, LIMITED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
San Carlos Milling Co. v. Commissioner
Docket No. 39525.
United States Board of Tax Appeals
24 B.T.A. 1132; 1931 BTA LEXIS 1533;
December 11, 1931, Promulgated
1. Petitioner operated a sugar mill in the Philippine Islands under contracts with planters of sugar cane, whereby it milled the cane produced by the planters, and accepted as compensation for its milling services a percentage of the manufactured sugar. Held, the sugar so received constituted income at the time and place received to the extent…
2Cases cited13 opinions
- Sturm v. BokerSupreme Court of the United States · 1893
- Ludvigh v. American Woolen Co. of NYSupreme Court of the United States · 1913
- Powder Co. v. BurkhardtSupreme Court of the United States · 1878
- United States v. RaymondSupreme Court of the United States · 1876
- Arnold v. HatchSupreme Court of the United States · 1900
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