Legal Opinion

H. T. Cushman Mfg. Co. v. Commissioner

United States Tax Court

Decided November 8, 1943No. Docket No. 734Unpublished

Payments by petitioner to an officer's widow, pursuant to a contract between petitioner and its officers authorizing such payments in the sum of $5,000 per annum, held, deductible under the provisions of section 19.23 (a)-9, Regulations 103, notwithstanding a provision in the contract that the amount of the payments in any year was to be reduced by the amount of dividends paid in that year upon stock of petitioner owned by the deceased officer on the date the contract was…

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Payments by petitioner to an officer's widow, pursuant to a contract between petitioner and its officers authorizing such payments in the sum of $5,000 per annum, held, deductible under the provisions of section 19.23 (a)-9, Regulations 103, notwithstanding a provision in the contract that the amount of the payments in any year was to be reduced by the amount of dividends paid in that year upon stock of petitioner owned by the deceased officer on the date the contract was executed.

1Opinion of the Court

H. T. Cushman Manufacturing Company v. Commissioner.

H. T. Cushman Mfg. Co. v. Commissioner

Docket No. 734.

United States Tax Court

1943 Tax Ct. Memo LEXIS 60; 2 T.C.M. (CCH) 978; T.C.M. (RIA) 43475;

November 8, 1943

Payments by petitioner to an officer's widow, pursuant to a contract between petitioner and its officers authorizing such payments in the sum of $5,000 per annum, held, deductible under the provisions of section 19.23 (a)-9, Regulations 103, notwithstanding a provision in the contract that the amount of the payments in any year was to be reduced by the amount of dividends paid in that…

2Cases cited2 opinions

  1. Seavey & Flarsheim Brokerage Co. v. CommissionerUnited States Board of Tax Appeals · 1940
  2. Astorian-Budget Publishing Co. v. CommissionerUnited States Board of Tax Appeals · 1941

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