Legal Opinion

Wasatch Chemical Company, a Utah Corporation v. Commissioner of Internal Revenue

Court of Appeals for the Tenth Circuit

Decided February 26, 1963No. 7062PublishedCited by 22 opinions

1Opinion of the Court

SETH, Circuit Judge.

The petitioner adopted a profit sharing pension plan and made contributions to the trust by delivery of its own unsecured, interest-bearing promissory notes with stated maturity dates. The question on this appeal is whether the delivery of such notes constituted “payment” to allow them as deductions on the petitioner’s income tax returns under Section 404 of the Internal Revenue Code of 1954.

More particularly the issues relate to asserted deficiencies in petitioner’s income tax for 1955 and 1956. The contribution to the trust administering the pension plan claimed as a…

2Cases cited7 opinions

  1. Time Oil Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
  2. Anthony P. Miller, Inc. v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1947
  3. Musselman Hub-Brake Co. v. Com'r of Internal RevenueCourt of Appeals for the Sixth Circuit · 1943
  4. Colorado Nat'l Bank v. CommissionerUnited States Tax Court · 1958
  5. Duffy Theatres, Inc. v. Griffith Consol. Theatres, Inc.Court of Appeals for the Tenth Circuit · 1953

2 more not listed; retrieve them via the Exa API.

3Cited by22 opinions

  1. Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
  2. F. & D. Rentals, Inc. v. CommissionerUnited States Tax Court · 1965
  3. Don E. Williams Co. v. CommissionerUnited States Tax Court · 1974
  4. Van Products, Inc. v. CommissionerUnited States Tax Court · 1963
  5. Don E. Williams Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1975

17 more not listed; retrieve them via the Exa API.

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