Strong Mfg. Co. v. Commissioner
United States Board of Tax Appeals
Contract requiring application of a portion of petitioner's earnings and profits for the taxable year against indebtedness incurred prior to 1936. held, to require irrevocable setting aside of such portion and to entitle petitioner to a credit for purposes of the undistributed profits tax to the extent that such payment was actually made in the taxable year. Revenue Act of 1936, sec. 26(c)(2).
1Opinion of the Court
THE STRONG MANUFACTURING COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Strong Mfg. Co. v. Commissioner
Docket No. 95626.
United States Board of Tax Appeals
41 B.T.A. 1273; 1940 BTA LEXIS 1070;
May 29, 1940, Promulgated
Contract requiring application of a portion of petitioner's earnings and profits for the taxable year against indebtedness incurred prior to 1936. held, to require irrevocable setting aside of such portion and to entitle petitioner to a credit for purposes of the undistributed profits tax to the extent that such payment was actually made in the taxable year.…
2Cases cited1 opinion
- Strong Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1940