United States Playing Card Co. v. Commissioner
United States Board of Tax Appeals
1. In 1921 the petitioner issued $800,000 of "Serial Debenture Gold Notes," which, it alleged, were sold through a bank at par, less a commission of 5 per cent. The petitioner paid to the bank so-called commissions of $40,000, plus $400 representing the cost of documentary stamps, and claimed the entire amount of $40,400 as a deduction from income for 1921. The respondent prorated the amount over the life of the notes, and allowed $8,206.25 as a deduction from 1921 income.
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1. In 1921 the petitioner issued $800,000 of "Serial Debenture Gold Notes," which, it alleged, were sold through a bank at par, less a commission of 5 per cent. The petitioner paid to the bank so-called commissions of $40,000, plus $400 representing the cost of documentary stamps, and claimed the entire amount of $40,400 as a deduction from income for 1921. The respondent prorated the amount over the life of the notes, and allowed $8,206.25 as a deduction from 1921 income. The petitioner kept its books upon an accrual basis. Held, that the $400 stamp tax constitutes an allowable deduction…
1Opinion of the Court
*979OPINION.
TRAmmell:
The first issue for consideration here is whether the respondent erred in amortizing or prorating so-called commissions and selling expenses over the life of certain gold notes issued by the petitioner in 1921. In that year the petitioner issued three series of “8 per cent Serial Debenture Gold Notes” in the total amount of $800,000 pursuant to the terms of the contract set out in our findings of fact above.
The petitioner claimed as a deduction from income for 1921 the amount of $40,400, consisting of $40,000 alleged to have been paid to the bankers as commissions for selling…
2Cited by18 opinions
- Washington v. CommissionerUnited States Tax Court · 1981
- State of Washington v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1982
- Lay v. CommissionerUnited States Tax Court · 1977
- James Bros. Coal Co. v. CommissionerUnited States Tax Court · 1964
- Commercial Inv. Trust Corp. v. CommissionerUnited States Board of Tax Appeals · 1933
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