Philadelphia-Baltimore Stock Exchange v. Commissioner
United States Tax Court
Petitioner in the taxable year 1944 reported in a single return the income and deductions pertaining to the operations of its business as a security exchange and the income and deductions from the operations of a Gratuity Fund established and maintained for its members. Petitioner claimed as a deduction the sum of $ 900 paid in 1944 as a "gratuity" to the widow of a former employee.
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Petitioner in the taxable year 1944 reported in a single return the income and deductions pertaining to the operations of its business as a security exchange and the income and deductions from the operations of a Gratuity Fund established and maintained for its members. Petitioner claimed as a deduction the sum of $ 900 paid in 1944 as a "gratuity" to the widow of a former employee. Held, the Exchange and the Gratuity Fund are separate entities for purposes of Federal taxation, and the filing of a single return was improper. Held, further, respondent's disallowance of the amount of $ 900 paid…
1Opinion of the Court
OPINION.
LeMire, Judge:
The respondent determined deficiencies in income tax and declared value excess-profits tax for the year 1944 in the respective amounts of $4,531.51 and $298.85, as a result of disallowing a deduction of $34,140, claimed by petitioner as payments from its Gratuity Fund to beneficiaries of deceased members, and a deduction of the sum of $900 paid to the widow of a former employee. Petitioner contends, in the alternative, that it is entitled to a deduction on account of payments made from the Gratuity Fund to the extent it reported, in a single return, the income from…
2Cases cited2 opinions
- Cedar Valley Distillery, Inc. v. CommissionerUnited States Tax Court · 1951
- I. Putnam, Inc. v. CommissionerUnited States Tax Court · 1950
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