Brizard Co. v. Commissioner
United States Tax Court
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
- East Coast Equipment Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1955
- Brewster Shirt Corp. v. CommissionerCourt of Appeals for the Second Circuit · 1947
- Elmer v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1933
- 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
- Pacific Affiliate, Inc. v. CommissionerUnited States Tax Court · 1952
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