Legal Opinion
Commissioner of Internal Revenue v. Gilt Edge Textile Corp.
Court of Appeals for the Third Circuit
Decided March 14, 1949No. 9653PublishedCited by 9 opinions
1Opinion of the Court
O’CONNELL, Circuit Judge. ■
The instant appeal poses the question whether a $30,000 payment made in 1942 by Gilt Edge Textile Corporation (“Gilt Edge”), the taxpayer, to one Philip Dimond, who was its president, treasurer, a director, and the majority stockholder, is deductible from its gross income under the provisions of Section 23(f) of the Internal Revenue Code, 26 U.S.C.A. § 23(f).
The facts are substantially as follows: One Louis Spitz, a business associate of Dimond in the Quackenbush Company, died in 1929. Dimond became one of the three executors of Spitz’ estate, estimated to be about…
2Cases cited15 opinions
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Kornhauser v. United StatesSupreme Court of the United States · 1928
- Hatfried, Inc. v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1947
- Hales-Mullaly, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1942
- Wright-Bernet v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
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3Cited by9 opinions
- Vincent v. CommissionerUnited States Tax Court · 1952
- Graham v. CommissionerUnited States Tax Court · 1963
- Kappel v. United StatesDistrict Court, W.D. Pennsylvania · 1968
- Reade Manufacturing Company, Inc., a Corporation of the State of New Jersey v. United StatesCourt of Appeals for the Third Circuit · 1962
- Justice Steel, Inc. v. CommissionerUnited States Tax Court · 1980
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