Legal Opinion
Burlington-Rock Island Railroad Company v. United States
Court of Appeals for the Fifth Circuit
Decided August 27, 1963No. 19700_1PublishedCited by 22 opinions
1Opinion of the Court
WISDOM, Circuit Judge.
This appeal is from the district court’s judgment denying plaintiff’s claim for an income tax refund. (S.D.Tex.1961), 200 F.Supp. 681.
The question for decision is whether the taxpayer, filing its returns on the calendar year, on an accrual basis, had a fixed and unconditional obligation in the taxable year 1954 to pay interest claimed as a deduction in that year. We affirm the district court’s holding that the obligation was not fixed and unconditional in 1954, and that therefore the taxpayer was not entitled to accrue and deduct the interest claimed in that year.
The…
2Cases cited17 opinions
- Guardian Investment Corporation v. Robert L. Phinney, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
- Fahs v. MartinCourt of Appeals for the Fifth Circuit · 1955
- Pierce Estates, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1952
- Alexander v. HandleyTexas Supreme Court · 1941
- United States v. Herbert W. Virgin, Jr.Court of Appeals for the Fifth Circuit · 1956
12 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Putoma Corp. v. CommissionerUnited States Tax Court · 1976
- Putoma Corp., Successor by Merger of Pro-Mac Company, Petitioners- Cross-Appellants v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1979
- Robbins Tire & Rubber Co. v. CommissionerUnited States Tax Court · 1969
- Trinity Construction Co., Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1970
- Casalina Corp. v. CommissionerUnited States Tax Court · 1973
17 more not listed; retrieve them via the Exa API.