Willamette Indus. v. Commissioner
United States Tax Court
P, an accrual method corporation, placed a letter of credit in trust to satisfy the estimated claims of a contested liability. Held: P may not deduct the contested liability. The letter of credit is not a transfer of money or other property within the meaning of sec. 461(f)(2), I.R.C. 1954.
1Opinion of the Court
OPINION
Scott, Judge:
These cases were assigned to Special Trial Judge Carleton D. Powell pursuant to the provisions of section 7456(d)(4) of the Code (redesignated section 7443A(b)(4) by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rule 180 et seq. of the Tax Court Rules of Practice and Procedure.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
POWELL, Special Trial Judge:
Respondent determined deficiencies in petitioner’s income taxes for the years and in the amounts as…
2Cases cited21 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- Eckert v. BurnetSupreme Court of the United States · 1931
- In Re Plywood Antitrust Litigation. French Quarter Apartments, Ltd. v. Georgia-Pacific Corporation, Georgia-Pacific Corporation v. Kohn, Savett, Marion & Graf, P. C., Movants-Appellees. Willamette Industries, Inc. v. Kohn, Savett, Marion & Graf, P. C., Movants-Appellees. Lyman Lamb Co. v. Georgia-Pacific CorporationCourt of Appeals for the Fifth Circuit · 1981
- Helvering v. PriceSupreme Court of the United States · 1940
16 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Concord Instruments Corp. v. CommissionerUnited States Tax Court · 1994
- Davies v. CommissionerUnited States Tax Court · 1993
- John E. Rogers & Frances L. Rogers v. CommissionerUnited States Tax Court · 2018
- Willamette Indus. v. CommissionerUnited States Tax Court · 1995
- Willamette Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1998
6 more not listed; retrieve them via the Exa API.