Legal Opinion

Hibbard, Spencer, Bartlett & Co. v. Commissioner

United States Board of Tax Appeals

Decided November 12, 1926No. Docket No. 7431Published

Amounts paid into a fund during each year for pensioning its employees are deductible from gross income for the year as ordinary and necessary expenses of carrying on the petitioner's business, where the facts and circumstances connected with the creation and operation of the fund show that it is a trust and a separate taxable entity.

1Opinion of the Court

HIBBARD, SPENCER, BARTLETT & CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Hibbard, Spencer, Bartlett & Co. v. Commissioner

Docket No. 7431.

United States Board of Tax Appeals

5 B.T.A. 464; 1926 BTA LEXIS 2851;

November 12, 1926, Decided

Amounts paid into a fund during each year for pensioning its employees are deductible from gross income for the year as ordinary and necessary expenses of carrying on the petitioner's business, where the facts and circumstances connected with the creation and operation of the fund show that it is a trust and a separate taxable entity.

David…

2Cases cited1 opinion

  1. Hibbard, Spencer, Bartlett & Co. v. CommissionerUnited States Board of Tax Appeals · 1926

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