Unitex Industries, Inc. v. Commissioner
United States Tax Court
Where preferred stock of the taxpayer-corporation was purchased from it in installments, the stock certificates not being issued until receipt from the subscribers of the final installments, and the taxpayer made periodic payments to the subscribers with respect to these installments, held, the periodic payments by the taxpayer do not constitute a deductible interest expense under section 23 (b) of the 1939 Code nor do they constitute ordinary and necessary expenses under…
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Where preferred stock of the taxpayer-corporation was purchased from it in installments, the stock certificates not being issued until receipt from the subscribers of the final installments, and the taxpayer made periodic payments to the subscribers with respect to these installments, held, the periodic payments by the taxpayer do not constitute a deductible interest expense under section 23 (b) of the 1939 Code nor do they constitute ordinary and necessary expenses under section 23 (a) (1) (A).
1Opinion of the Court
Unitex Industries, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Unitex Industries, Inc. v. Commissioner
Docket No. 58752
United States Tax Court
30 T.C. 468; 1958 U.S. Tax Ct. LEXIS 176;
May 29, 1958, Filed
Decision will be entered under Rule 50.
Where preferred stock of the taxpayer-corporation was purchased from it in installments, the stock certificates not being issued until receipt from the subscribers of the final installments, and the taxpayer made periodic payments to the subscribers with respect to these installments, held, the periodic payments by the taxpayer do not…
2Cases cited8 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- United States v. Title Guarantee & Trust Co.Court of Appeals for the Sixth Circuit · 1943
- United States v. South Georgia Ry. Co.Court of Appeals for the Fifth Circuit · 1939
- Haffenreffer Brewing Co. v. Commissioner of Int. Rev.Court of Appeals for the First Circuit · 1940
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