Legal Opinion

Newlin Machinery Corp. v. Commissioner

United States Tax Court

Decided June 28, 1957No. Docket No. 63750Published

1. Petitioner, a corporation, sold heavy machinery and related equipment to political subdivisions in Missouri and Kansas. The unpaid portion of the purchase price was paid in semiannual installments under lease arrangements. Some transactions were not evidenced by any written obligation to pay interest. Some transactions were evidenced by signed purchase orders providing for the payment of interest.

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1. Petitioner, a corporation, sold heavy machinery and related equipment to political subdivisions in Missouri and Kansas. The unpaid portion of the purchase price was paid in semiannual installments under lease arrangements. Some transactions were not evidenced by any written obligation to pay interest. Some transactions were evidenced by signed purchase orders providing for the payment of interest. Held, of the amounts in dispute, the amounts attributable to transactions not evidenced by written obligations which, on their face, provided for the payment of interest, are not tax exempt…

1Opinion of the Court

Newlin Machinery Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Newlin Machinery Corp. v. Commissioner

Docket No. 63750

United States Tax Court

28 T.C. 837; 1957 U.S. Tax Ct. LEXIS 145;

June 28, 1957, Filed

Decision will be entered under Rule 50.

1. Petitioner, a corporation, sold heavy machinery and related equipment to political subdivisions in Missouri and Kansas. The unpaid portion of the purchase price was paid in semiannual installments under lease arrangements. Some transactions were not evidenced by any written obligation to pay interest. Some transactions were…

2Cases cited14 opinions

  1. Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
  2. Krim-Ko Corp. v. CommissionerUnited States Tax Court · 1951
  3. State ex rel. Boynton v. Board of EducationSupreme Court of Kansas · 1933
  4. Newlin Machinery Corp. v. CommissionerUnited States Tax Court · 1957
  5. Kings County D. Co. v. Commissioner of Internal Rev.Court of Appeals for the Ninth Circuit · 1937

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