Legal Opinion
Commissioner of Internal Revenue v. HP Hood & Sons
Court of Appeals for the First Circuit
Decided March 22, 1944No. 3945PublishedCited by 27 opinions
1Opinion of the Court
MAHONEY, Circuit Judge.
The question here involved is whether amounts accrued by the taxpayer as interest payable on its “7% Income Debentures” are deductible as interest on indebtedness under § 23(b) of the Revenue Acts of 1936 and 1938, 1 or nondeductible as being in fact dividends on preferred stock. The taxes in controversy are income taxes for the fiscal year of the respondent ended February 28, 1938, in the sum of $25,089.29 and income and excess profits taxes for its fiscal year ended February 28, 1939, in the aggregate sum of $46,860.46.
The taxpayer is a Massachusetts corporation…
2Cases cited5 opinions
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Bullen v. WisconsinSupreme Court of the United States · 1916
- Commissioner of Internal Revenue v. OPP Holding Corp.Court of Appeals for the Second Circuit · 1935
- Commissioner of Internal Revenue v. Proctor ShopCourt of Appeals for the Ninth Circuit · 1936
- Haffenreffer Brewing Co. v. Commissioner of Int. Rev.Court of Appeals for the First Circuit · 1940
3Cited by27 opinions
- P. M. Finance Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
- Wilbur Sec. Co. v. CommissionerUnited States Tax Court · 1959
- Talbot Mills v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1944
- Commissioner of Internal Revenue v. John Kelley Co.Court of Appeals for the Seventh Circuit · 1944
- Monon Railroad v. CommissionerUnited States Tax Court · 1970
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