Virginia Iron Coal & Coke Co. v. Commissioner
United States Board of Tax Appeals
Payments received in 1930 and 1931 under an option to purchase which were to be applied upon the purchase price in case the option were exercised but which were to be retained in case the option were not exercised, were income of the year in which the option was surrendered.
1Opinion of the Court
*196OPINION.
Murdock: The Commissioner determined for the year 1933 a deficiency of $51,178.95 in income tax and a deficiency of $4,229.42 in excess profits tax of the petitioner and its affiliated companies. The sole issue for decision is whether or not the Commissione»»erred in including in consolidated income for 1933, $425,000 representing payments received by the affiliated companies in prior years under a contract with the Texas Gulf Sulphur Co. The facts have been stipulated and no findings of fact need be made.
The petitioner owned practically all of the stock of its subsidiary, the New…
2Cited by28 opinions
- Saviano v. CommissionerUnited States Tax Court · 1983
- Elrod v. CommissionerUnited States Tax Court · 1986
- Virginia Iron Coal & Coke Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1938
- Dunlap v. CommissionerUnited States Tax Court · 1980
- Paul D. Dunlap and Shirley A. Dunlap, Hawkeye Bancorporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1982
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