Dillard Paper Co. v. Commissioner
United States Tax Court
Held, long-term capital loss in the amount of $ 12,918.87 realized upon the transfer of securities by petitioner to the fiduciary of its employees' profit-sharing trust as its contribution under its profit-sharing plan is not deductible by reason of section 267 of the Internal Revenue Code of 1954.
1Opinion of the Court
OPINION
Bruce, Judge:
Respondent determined a deficiency in the income tax of petitioner for the taxable year 1958 in the amount of $1,735.65. The sole issue is whether petitioner is entitled to a deduction ás a long-term capital loss in the amount of $12,918.87 resulting from its transfer of securities to the fiduciary of its profit-sharing trust in payment of its contribution thereto.
All of the facts are stipulated and are found accordingly.
Petitioner is a corporation organized under the laws of the State of North Carolina with its principal place of business in Greensboro, N.C., and is…
2Cases cited3 opinions
- United States v. General Shoe CorporationCourt of Appeals for the Sixth Circuit · 1960
- Radom & Neidorff, Inc. v. United StatesUnited States Court of Claims · 1960
- Hydro Molding Co. v. CommissionerUnited States Tax Court · 1962
3Cited by3 opinions
- Dillard Paper Company v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1965
- Hickman v. CommissionerUnited States Tax Court · 1972
- Dillard Paper Co. v. CommissionerUnited States Tax Court · 1964