Oregon City Mfg. Co. v. Commissioner
United States Board of Tax Appeals
Credit under section 26(c)(1) and (2), Revenue Act of 1936, not allowed where indenture of trust to secure an issue of bonds simply requires the petitioner to accumulate its net earnings until the operating capital of the company reaches the amount of $175,000.
1Opinion of the Court
OPINION.
Smith :
These proceedings, consolidated for hearing, involve income tax deficiencies for 1936 and 1937 of $12,322.15 and $4,680.45, respectively. The question in issue is whether the petitioner is entitled, under section 26 (c) (1) and (2) of the Revenue Act of 1936; to credits of $60,047.37 and $24,494.07 for 1936 and 1937, respectively, for contracts restricting the payment of dividends.
The proceedings have been submitted to the Board upon the pleadings, a signed stipulation of facts, and certain exhibits. These establish the following:
1. The petitioner is an Oregon corporation with…
2Cases cited1 opinion
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
3Cited by3 opinions
- Oregon City Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1940
- Paraport Theatre Leasing Corp. v. CommissionerUnited States Board of Tax Appeals · 1941
- Paris & M. P. R. Co. v. CommissionerUnited States Board of Tax Appeals · 1942