Floyd, Inc. v. Commissioner
United States Board of Tax Appeals
PERSONAL HOLDING COMPANY SURTAX - INDEBTEDNESS. - On December 31, 1934, petitioner set aside in a reserve fund an amount to be applied on the payment of income tax deficiencies for 1930 and 1931 proposed in a deficiency notice mailed on June 8, 1934. Held that the petitioner's liability for income tax for 1930 and 1931 was incurred in each of those years; that the liability for such taxes so incurred constituted an "indebtedness incurred prior to January 1, 1934" within the…
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PERSONAL HOLDING COMPANY SURTAX - INDEBTEDNESS. - On December 31, 1934, petitioner set aside in a reserve fund an amount to be applied on the payment of income tax deficiencies for 1930 and 1931 proposed in a deficiency notice mailed on June 8, 1934. Held that the petitioner's liability for income tax for 1930 and 1931 was incurred in each of those years; that the liability for such taxes so incurred constituted an "indebtedness incurred prior to January 1, 1934" within the meaning of section 351(b)(2)(B) of the Revenue Act of 1934; that the amount set aside to retire such indebtedness was…
1Opinion of the Court
FLOYD, INCORPORATED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Floyd, Inc. v. Commissioner
Docket No. 99562.
United States Board of Tax Appeals
43 B.T.A. 101; 1940 BTA LEXIS 847;
December 18, 1940, Promulgated
PERSONAL HOLDING COMPANY SURTAX - INDEBTEDNESS. - On December 31, 1934, petitioner set aside in a reserve fund an amount to be applied on the payment of income tax deficiencies for 1930 and 1931 proposed in a deficiency notice mailed on June 8, 1934. Held that the petitioner's liability for income tax for 1930 and 1931 was incurred in each of those years; that the liability…
2Cases cited10 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Billings v. United StatesSupreme Court of the United States · 1914
- Price v. United StatesSupreme Court of the United States · 1926
- Hygienic Products Co. v. CommissionerUnited States Board of Tax Appeals · 1938
- United States v. ProctorDistrict Court, S.D. Texas · 1922
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