Legal Opinion

Brizard Co. v. Commissioner

United States Tax Court

Decided September 10, 1957No. Docket No. 54923Published

Held, amounts received by petitioner as a result of the assignment to the Bank of America of promissory notes and conditional sales contracts do not qualify as borrowed capital within the meaning of section 439, I. R. C. 1939.

1Opinion of the Court

Brizard Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Brizard Co. v. Commissioner

Docket No. 54923

United States Tax Court

28 T.C. 1142; 1957 U.S. Tax Ct. LEXIS 97;

September 10, 1957, Filed

Decision will be entered for the respondent.

Held, amounts received by petitioner as a result of the assignment to the Bank of America of promissory notes and conditional sales contracts do not qualify as borrowed capital within the meaning of section 439, I. R. C. 1939.

L. W. Wrixon, Esq., for the petitioner.

Aaron S. Resnik, Esq., for the respondent.

Withey, Judge.

WITHEY

The respondent…

2Cases cited9 opinions

  1. East Coast Equipment Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1955
  2. Brewster Shirt Corp. v. CommissionerCourt of Appeals for the Second Circuit · 1947
  3. Elmer v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1933
  4. Commissioner of Internal Revenue v. Pacific Affiliate, Inc., a Corporation, Pacific Affiliate, Inc., a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
  5. Pacific Affiliate, Inc. v. CommissionerUnited States Tax Court · 1952

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