Hamilton Nat'l Bank v. Commissioner
United States Board of Tax Appeals
The amount of the principal of a promissory note payable on or before July 7, 1930, representing profit on a sale returnable on the installment basis, and interest thereon, is held to have been constructively received in 1929, where the agent of the maker in 1929 tendered payment in cash, and, upon refusal of the holder to accept payment, of his own volition deposited the amount in a savings account in his own name as trustee, and delivered to an officer of the bank the…
Read the full summary
The amount of the principal of a promissory note payable on or before July 7, 1930, representing profit on a sale returnable on the installment basis, and interest thereon, is held to have been constructively received in 1929, where the agent of the maker in 1929 tendered payment in cash, and, upon refusal of the holder to accept payment, of his own volition deposited the amount in a savings account in his own name as trustee, and delivered to an officer of the bank the passbook and a check drawn to the order of the payee dated January 10, 1930, for the amount deposited and bank interest to…
1Opinion of the Court
THE HAMILTON NATIONAL BANK OF CHATTANOOGA, AS ADMINISTRATOR OF THE ESTATE OF S. STRANG NICKLIN, DECEASED, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Hamilton Nat'l Bank v. Commissioner
Docket No. 66833.
United States Board of Tax Appeals
29 B.T.A. 63; 1933 BTA LEXIS 1005;
October 3, 1933, Promulgated
The amount of the principal of a promissory note payable on or before July 7, 1930, representing profit on a sale returnable on the installment basis, and interest thereon, is held to have been constructively received in 1929, where the agent of the maker in 1929 tendered payment in…
2Cases cited2 opinions
- Hamilton National Bank of Chattanooga v. CommissionerUnited States Board of Tax Appeals · 1933
- Hamilton Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1933