Legal Opinion

A. Harris & Co. v. Commissioner

United States Board of Tax Appeals

Decided May 27, 1929No. Docket Nos. 12123, 13998, 22502Published

1. Amounts paid by the petitioner in its fiscal years ended January 31, 1920, 1921, and 1922, to former creditors whose claims had been discharged by composition in 1915, held not to be ordinary and necessary expenses of its business, nor deductible from the income of those years. 2. Interest-bearing promissory notes of solvent and responsible makers, actually and bona fide paid in for stock of a Texas corporation, constitute invested capital of such corporation at the time…

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1. Amounts paid by the petitioner in its fiscal years ended January 31, 1920, 1921, and 1922, to former creditors whose claims had been discharged by composition in 1915, held not to be ordinary and necessary expenses of its business, nor deductible from the income of those years. 2. Interest-bearing promissory notes of solvent and responsible makers, actually and bona fide paid in for stock of a Texas corporation, constitute invested capital of such corporation at the time paid in to the extent of their actual fair market value. 3. Where a tax return for the fiscal year ended January 31,…

1Opinion of the Court

A. HARRIS & CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

A. Harris & Co. v. Commissioner

Docket Nos. 12123, 13998, 22502.

United States Board of Tax Appeals

16 B.T.A. 705; 1929 BTA LEXIS 2533;

May 27, 1929, Promulgated

1. Amounts paid by the petitioner in its fiscal years ended January 31, 1920, 1921, and 1922, to former creditors whose claims had been discharged by composition in 1915, held not to be ordinary and necessary expenses of its business, nor deductible from the income of those years.

2. Interest-bearing promissory notes of solvent and responsible makers, actually and…

2Cases cited4 opinions

  1. Hewitt Rubber Co. v. CommissionerUnited States Board of Tax Appeals · 1925
  2. John Wanamaker Philadelphia v. CommissionerUnited States Board of Tax Appeals · 1927
  3. A. Harris & Co. v. CommissionerUnited States Board of Tax Appeals · 1929
  4. American Steel Co. v. CommissionerUnited States Board of Tax Appeals · 1925

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