Pacific Flush--Tank Co. v. Commissioner
United States Board of Tax Appeals
DIVIDENDS PAID CREDIT. - Petitioner, on the accrual basis, issued its notes in December 1937, for salary bonuses and on account of such accrued expense was allowed a deduction from gross income for 1937. In 1938 such notes were paid in full. Held, that petitioner is entitled to a dividends paid credit under section 27(a)(4), Revenue Act of 1938, for the amount used to pay off such notes.
1Opinion of the Court
*871OPINION.
Tyson :
There is no controversy herein as to the amount of $20,100 used by petitioner to retire its indebtedness in 1938 being reasonable with respect to the size and terms of such indebtedness.
The respondent contends that the instant case is specifically covered by the applicable regulations, upon which he relies as the correct construction of section 27 (a) (4), supra; that that section contains ambiguities which require interpretation to effectuate the legislative intent; and that, in the absence of statutory language clearly granting a double deduction or tax benefit for the same…
2Cited by2 opinions
- Sabine Transp. Co. v. CommissionerCourt of Appeals for the Fifth Circuit · 1942
- Pacific Flush--Tank Co. v. CommissionerUnited States Board of Tax Appeals · 1941