Legal Opinion
Commissioner of Internal Revenue v. John Kelley Co.
Court of Appeals for the Seventh Circuit
Decided December 21, 1944No. 8426PublishedCited by 15 opinions
1Opinion of the Court
MINTON, Circuit Judge.
The Commissioner of Internal Revenue determined deficiencies in income and excess profits tax against the taxpayer, the John Kelley Company for the calendar years 1937, 1938, 1939. The Tax Court refused to sustain the assessment, and the Commissioner has petitioned for review. The alleged deficiencies arose from the taxpayer’s deduction of payments made on income debentures as interest on indebtedness. The Commissioner contends that the payments were dividends within the meaning of section 115(a) and not interest within the meaning of section 23(b) of the Revenue Act of…
2Cases cited13 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner of Int. Rev. v. Meridian & Thirteenth R. Co.Court of Appeals for the Seventh Circuit · 1942
- Commissioner of Internal Revenue v. OPP Holding Corp.Court of Appeals for the Second Circuit · 1935
- Commissioner of Internal Revenue v. Proctor ShopCourt of Appeals for the Ninth Circuit · 1936
- United States v. Title Guarantee & Trust Co.Court of Appeals for the Sixth Circuit · 1943
8 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Kraft Foods Company v. Commissioner of Internal Revenue, (Two Cases)Court of Appeals for the Second Circuit · 1956
- Georgia-Pacific Corp. v. CommissionerUnited States Tax Court · 1975
- International Ladies' Garment Workers' Union v. Donnelly Garment Co.Court of Appeals for the Eighth Circuit · 1945
- Wilbur Sec. Co. v. CommissionerUnited States Tax Court · 1959
10 more not listed; retrieve them via the Exa API.