Newlin Machinery Corp. v. Commissioner
United States Tax Court
1. Petitioner, a corporation, sold heavy machinery and related equipment to political subdivisions in Missouri and Kansas. The unpaid portion of the purchase price was paid in semiannual installments under lease arrangements. Some transactions were not evidenced by any written obligation to pay interest. Some transactions were evidenced by signed purchase orders providing for the payment of interest.
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1. Petitioner, a corporation, sold heavy machinery and related equipment to political subdivisions in Missouri and Kansas. The unpaid portion of the purchase price was paid in semiannual installments under lease arrangements. Some transactions were not evidenced by any written obligation to pay interest. Some transactions were evidenced by signed purchase orders providing for the payment of interest. Held, of the amounts in dispute, the amounts attributable to transactions not evidenced by written obligations which, on their face, provided for the payment of interest, are not tax exempt…
1Opinion of the Court
OPINION.
HaRRon, Judge:
Issue 1. Tasc-Emempt Interest.
Petitioner sold heavy machinery and related equipment to political subdivisions in the States of Missouri and Kansas. In some instances, the municipalities entered into lease agreements in order to pay the purchase price, or unpaid portion thereof, in semiannual installments over a period of years. Petitioner claimed in its returns for the fiscal years ended June 80,1952 and 1953, that receipts by these political subdivisions in the amounts of $7,934.92 and $5,102.25, respectively, constituted tax-exempt interest within the meaning of…
2Cases cited13 opinions
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Krim-Ko Corp. v. CommissionerUnited States Tax Court · 1951
- State ex rel. Boynton v. Board of EducationSupreme Court of Kansas · 1933
- Kings County D. Co. v. Commissioner of Internal Rev.Court of Appeals for the Ninth Circuit · 1937
- Union National Bank & Trust Co. of Elgin v. CommissionerUnited States Tax Court · 1956
8 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Ewing v. Comm'rUnited States Tax Court · 2004
- Stevens Bros. Foundation, Inc. v. CommissionerUnited States Tax Court · 1962
- Porter v. Comm'rUnited States Tax Court · 2008
- Estate of O'Daniel v. United StatesCourt of Appeals for the Fifth Circuit · 1993
- First Nat'l Bank v. CommissionerUnited States Tax Court · 1965
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