Greer-Robbins Co. v. Commissioner

DENMAN, Circuit Judge.

The petitioning taxpayer, Greer-Robbins Company, seeks review of a decision of the Board of Tax Appeals upholding the Commissioner’s deficiency assessment for the tax year 1935, based upon an accrual of interest to taxpayer, which kept its books on an accrual basis, upon moneys loaned by it to Union Motors, Inc. It is not questioned that the interest in the amount found by the Commissioner was owed by Union Motors, Inc., to taxpayer and had accrued in the tax period in question, or that in ordinary circumstances it would have been a part of taxpayer’s taxable income.

Taxpa…