Legal Opinion

Davidson-Boutell Co. v. Commissioner

United States Tax Court

Decided July 13, 1943No. Docket No. 111958Unpublished

Petitioner's promise in a trust indenture to set aside, on or before a date after the close of the taxable year, a stated amount of its earnings for such taxable year, held not to constitute an irrevocable setting aside of funds to retire indebtedness, within the purview of section 27(a)(4) of the Internal Revenue Code and Regulations 103, section 19.27(a)-3(b).

1Opinion of the Court

Davidson-Boutell Company v. Commissioner.

Davidson-Boutell Co. v. Commissioner

Docket No. 111958.

United States Tax Court

1943 Tax Ct. Memo LEXIS 198; 2 T.C.M. (CCH) 449; T.C.M. (RIA) 43342;

July 13, 1943

Petitioner's promise in a trust indenture to set aside, on or before a date after the close of the taxable year, a stated amount of its earnings for such taxable year, held not to constitute an irrevocable setting aside of funds to retire indebtedness, within the purview of section 27(a)(4) of the Internal Revenue Code and Regulations 103, section 19.27(a)-3(b).

Denver A. Busby, C.P.A., 120 S. La…

2Cases cited2 opinions

  1. Securities Co. of New Jersey v. CommissionerUnited States Board of Tax Appeals · 1941
  2. L. O. Koven & Bro., Inc. v. CommissionerUnited States Board of Tax Appeals · 1942

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