Slaymaker Lock Co. v. Commissioner
United States Tax Court
1. Petitioner, accounting on the accrual basis, executed and delivered to an exempt pension trust its demand negotiable promissory note on the last day of its taxable year. It thereafter made a partial payment and substituted its demand negotiable promissory note for the balance due on the original note, within 60 days after the close of its taxable year, but did not discharge either note by actual payment within that period.
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1. Petitioner, accounting on the accrual basis, executed and delivered to an exempt pension trust its demand negotiable promissory note on the last day of its taxable year. It thereafter made a partial payment and substituted its demand negotiable promissory note for the balance due on the original note, within 60 days after the close of its taxable year, but did not discharge either note by actual payment within that period. Held, delivery of such notes was not payment within 60 days after the close of the taxable year of the amount accrued in that year, as required by section 23 (p) (1) (E)…
1Opinion of the Court
Slaymaker Lock Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Slaymaker Lock Co. v. Commissioner
Docket No. 24648
United States Tax Court
18 T.C. 1001; 1952 U.S. Tax Ct. LEXIS 106;
September 15, 1952, Promulgated
Decision will be entered under Rule 50.
1. Petitioner, accounting on the accrual basis, executed and delivered to an exempt pension trust its demand negotiable promissory note on the last day of its taxable year. It thereafter made a partial payment and substituted its demand negotiable promissory note for the balance due on the original note, within 60 days after the…
2Cases cited11 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Utah Power & Light Co. v. United StatesSupreme Court of the United States · 1917
- Spiegel v. CommissionerUnited States Tax Court · 1949
- PG Lake, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1945
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