Legal Opinion

Connolly Tool & Engineering Co. v. Commissioner

United States Tax Court

Decided July 27, 1964No. Docket No. 4855-62UnpublishedCited by 1 opinion

Held, petitioner's opening inventory for computing cost of goods sold is zero since its basis in the inventories resulting from a tax-free exchange is zero. Held, further, a bonus authorized in 1958 payable "as soon as funds become available to permit such payment without undue inconvenience to the corporation" is deductible by petitioner, an accrual basis taxpayer, in its taxable year, ended August 31, 1960, in which the required funds became available.

1Opinion of the Court

Connolly Tool & Engineering Co. v. Commissioner.

Connolly Tool & Engineering Co. v. Commissioner

Docket No. 4855-62.

United States Tax Court

T.C. Memo 1964-202; 1964 Tax Ct. Memo LEXIS 135; 23 T.C.M. (CCH) 1222; T.C.M. (RIA) 64202;

July 27, 1964

Held, petitioner's opening inventory for computing cost of goods sold is zero since its basis in the inventories resulting from a tax-free exchange is zero.

Held, further, a bonus authorized in 1958 payable "as soon as funds become available to permit such payment without undue inconvenience to the corporation" is deductible by petitioner, an accrual basis…

2Cases cited14 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
  3. Ezo Products Co. v. CommissionerUnited States Tax Court · 1961
  4. Frank G. Wikstrom & Sons, Inc. v. CommissionerUnited States Tax Court · 1953
  5. PA Birren & Son v. COMMISSIONER OF INTERNAL REVENUECourt of Appeals for the Seventh Circuit · 1940

9 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. D. N. Stafford and Flora C. Stafford v. United StatesCourt of Appeals for the Fifth Circuit · 1980

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