Legal Opinion

Tallman Tool & Machine Corp. v. Commissioner

United States Tax Court

Decided November 27, 1956No. Docket No. 60626Published

Profit-Sharing Trust -- Validity of Trust. -- The petitioner, an accrual basis taxpayer, executed a profit-sharing plan and trust, and delivered its $ 20,000 demand promissory note to the trust on September 30, 1952, the last day of its fiscal year. $ 22,520 cash was paid within the following 60-day period allowed by the statute for actual payment, being payment of the note and an additional amount to fulfill the petitioner's obligation under the plan.

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Profit-Sharing Trust -- Validity of Trust. -- The petitioner, an accrual basis taxpayer, executed a profit-sharing plan and trust, and delivered its $ 20,000 demand promissory note to the trust on September 30, 1952, the last day of its fiscal year. $ 22,520 cash was paid within the following 60-day period allowed by the statute for actual payment, being payment of the note and an additional amount to fulfill the petitioner's obligation under the plan. The cash payment within the grace period and the note, which under New York law was issued for valuable consideration, provided the trust with…

1Opinion of the Court

Tallman Tool & Machine Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Tallman Tool & Machine Corp. v. Commissioner

Docket No. 60626

United States Tax Court

27 T.C. 372; 1956 U.S. Tax Ct. LEXIS 33;

November 27, 1956, Filed

Decision will be entered under Rule 50.

Profit-Sharing Trust -- Validity of Trust. -- The petitioner, an accrual basis taxpayer, executed a profit-sharing plan and trust, and delivered its $ 20,000 demand promissory note to the trust on September 30, 1952, the last day of its fiscal year. $ 22,520 cash was paid within the following 60-day period allowed by…

2Cases cited4 opinions

  1. 555, Inc. v. CommissionerUnited States Tax Court · 1950
  2. Blanco v. VelezNew York Court of Appeals · 1946
  3. Tallman Tool & Machine Corp. v. CommissionerUnited States Tax Court · 1956
  4. Dejay Stores v. RyanCourt of Appeals for the Second Circuit · 1956

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