Legal Opinion

Joy Mfg. Co. v. Commissioner

United States Tax Court

Decided March 31, 1955No. Docket No. 49773Published

1. Income -- Accrual -- Fees -- Prior Commitment as to Use. -- Fees, which a wholly owned subsidiary agreed to pay to its parent for services, did not cease to be income to the parent on an accrual basis after the parent, in order to strengthen the credit of the subsidiary and to give it more capital, agreed to invest the fees, up to a stated amount, in capital stock of the subsidiary. 2. Income -- Accrual -- Fees -- Collectibility. -- There was no reason during the taxable…

Read the full summary

1. Income -- Accrual -- Fees -- Prior Commitment as to Use. -- Fees, which a wholly owned subsidiary agreed to pay to its parent for services, did not cease to be income to the parent on an accrual basis after the parent, in order to strengthen the credit of the subsidiary and to give it more capital, agreed to invest the fees, up to a stated amount, in capital stock of the subsidiary. 2. Income -- Accrual -- Fees -- Collectibility. -- There was no reason during the taxable years to doubt the ability of the subsidiary to pay the fees because of poor financial condition or business prospects.

1Opinion of the Court

Joy Manufacturing Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Joy Mfg. Co. v. Commissioner

Docket No. 49773

United States Tax Court

23 T.C. 1082; 1955 U.S. Tax Ct. LEXIS 214;

March 31, 1955, Filed

Decision will be entered for the respondent.

1. Income -- Accrual -- Fees -- Prior Commitment as to Use. -- Fees, which a wholly owned subsidiary agreed to pay to its parent for services, did not cease to be income to the parent on an accrual basis after the parent, in order to strengthen the credit of the subsidiary and to give it more capital, agreed to invest the fees, up to a…

2Cases cited1 opinion

  1. Joy Mfg. Co. v. CommissionerUnited States Tax Court · 1955

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API