Legal Opinion
Roberts Filter Mfg. Co. v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided March 25, 1949No. 9680PublishedCited by 3 opinions
1Opinion of the Court
O’CONNELL, Circuit Judge.
With four judges dissenting, the Tax Court has upheld the disallowance by the Commissioner of a $40,000 deduction claimed by petitioner in its 1941 tax return as “extra -compensation.” 1948, 10 T. C. 26. Petitioner here urges that the deduction was authorized by the “ordinary and necessary expenses” provision of section 23 of the Internal Revenue Code, 26 U. S.C.A. § 23(a).1
Petitioner, on an accrual calendar-year tax basis, designs and manufactures equipment for filtration plants of municipalities and industries.2 On December 31, 1941, all but a few shares of the…
2Cases cited3 opinions
- Clark Thread Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1938
- Lincoln Electric Co. v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1947
- Robertson v. Steele's MillsCourt of Appeals for the Fourth Circuit · 1949
3Cited by3 opinions
- Commissioner of Internal Revenue v. Surface Combustion CorporationCourt of Appeals for the Sixth Circuit · 1950
- Slaymaker Lock Co. v. CommissionerUnited States Tax Court · 1952
- Slaymaker Lock Co. v. CommissionerUnited States Tax Court · 1952