United States Steel Corp. v. Commissioner
United States Tax Court
Under the stock subscription plan here involved, where petitioner's employees could make application to purchase a limited number of shares of petitioner's stock and make deferred monthly payments therefor from wages, and petitioner agreed on its part to make certain credits to the employees' stock purchase accounts equaling the dividends paid on the company's common stock and other annual credits in the form of special benefits and additional compensation, which credits and…
Read the full summary
Under the stock subscription plan here involved, where petitioner's employees could make application to purchase a limited number of shares of petitioner's stock and make deferred monthly payments therefor from wages, and petitioner agreed on its part to make certain credits to the employees' stock purchase accounts equaling the dividends paid on the company's common stock and other annual credits in the form of special benefits and additional compensation, which credits and delivery of the stock were specifically conditioned upon the employee remaining in petitioner's service until the stock…
1Opinion of the Court
OPINION.
Habron, Judge:
The only question presented is whether the total of the amounts credited, by petitioner to certain employees’ stock subscription accounts which became fully paid in 1930, i. e., $1,002,-468.50, constitutes dividends or additional compensation for services. If said amount constitutes additional compensation for services, the amount is deductible in 1930. With respect to the year of the deduction, no issue is raised. Cf. Electric Storage Battery Co., 39 B. T. A. 121.
Petitioner contends that, pursuant to section 23 (a) of the Revenue Act of 1928,1 it is entitled to deduct…
2Cases cited2 opinions
- O'BRIEN v. MillerSupreme Court of the United States · 1897
- Kruse v. Hudson County Consumers Brewing Co.New Jersey Court of Chancery · 1911
3Cited by15 opinions
- Commissioner of Internal Revenue v. R. J. Reynolds Tobacco CompanyCourt of Appeals for the Fourth Circuit · 1958
- William C. Atwater & Co. v. CommissionerUnited States Tax Court · 1948
- Nicolson v. CommissionerUnited States Tax Court · 1949
- R. J. Reynolds Tobacco Co. v. CommissionerUnited States Tax Court · 1956
- W. T. Grant Co. v. CommissionerUnited States Tax Court · 1972
10 more not listed; retrieve them via the Exa API.