Legal Opinion

Fraser-Smith Co. v. Commissioner

United States Tax Court

Decided May 19, 1950No. Docket No. 18375Published

Petitioner drew sight drafts on its customers, payable to its bank, to which it attached bills of lading endorsed in blank. The instruments were delivered to the bank, which credited petitioner's account with the face amount of the drafts and allowed it to draw immediately against that credit. Held, the amounts credited are not borrowed capital within the meaning of section 719 (a) (1) of the Internal Revenue Code.

1Opinion of the Court

Fraser-Smith Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Fraser-Smith Co. v. Commissioner

Docket No. 18375

United States Tax Court

14 T.C. 892; 1950 U.S. Tax Ct. LEXIS 195;

May 19, 1950, Promulgated

Decision will be entered for the respondent.

Petitioner drew sight drafts on its customers, payable to its bank, to which it attached bills of lading endorsed in blank. The instruments were delivered to the bank, which credited petitioner's account with the face amount of the drafts and allowed it to draw immediately against that credit. Held, the amounts credited are not…

2Cases cited11 opinions

  1. Burton v. United StatesSupreme Court of the United States · 1905
  2. City of Douglas v. Federal Reserve Bank of DallasSupreme Court of the United States · 1926
  3. Vickers v. Machinery Warehouse & Sales Co.Washington Supreme Court · 1920
  4. Player Realty Co. v. CommissionerUnited States Tax Court · 1947
  5. Union Electric Steel Co. v. Imperial BankCourt of Appeals for the Third Circuit · 1923

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