Campbell Chain Co. v. Commissioner
United States Tax Court
Time -- Last Day on Holiday -- Sec. 23 (p) (1) (E), I. R. C. -- Deduction of contribution made to employees' trust by taxpayer on accrual basis, when contribution paid on day following end of 60-day period provided in section 23 (p) (1) (E), allowed when last day of 60-day period was Memorial Day, a legal holiday.
1Opinion of the Court
OPINION.
Tietjens, Judge:
Respondent having denied a deduction of $75,-569.94, determined deficiencies of $6,873.15 in income tax and $39,-791.90 in excess profits tax against petitioner for the fiscal year ended March 31, 1946. The petitioner kept its books on the accrual basis for its fiscal year ending March 31 and filed its tax returns accordingly. On March 31, 1946, petitioner accrued as a contribution to a profit sharing trust meeting the requirements of an exempt trust under section 165 (a) for the fiscal year ending on that date, the sum of $75,-569.94. This contribution was actually…
2Cases cited2 opinions
- Union National Bank v. LambSupreme Court of the United States · 1949
- Sherwood Bros. v. District of ColumbiaCourt of Appeals for the D.C. Circuit · 1940
3Cited by8 opinions
- General Lead Batteries Co. v. CommissionerUnited States Tax Court · 1953
- Hydro Molding Co. v. CommissionerUnited States Tax Court · 1962
- E-B Grain Co. v. CommissionerUnited States Tax Court · 1983
- Campbell Chain Co. v. CommissionerUnited States Tax Court · 1951
- E-B Grain Co. v. CommissionerUnited States Tax Court · 1983
3 more not listed; retrieve them via the Exa API.