L. O. Koven & Bro., Inc. v. Commissioner
United States Board of Tax Appeals
Petitioner, in 1933, entered into a written agreement with the holder of its bond. The agreement provided that from 1933 on petitioner would set aside from its yearly profits, as a reserve, the sum of $15,624.24 (10 percent of the debt). Until the bond was paid only the yearly profits in excess of the amount to be set aside could be used for the payment of dividends. During each of the years 1936 and 1937 petitioner added $15,624.24 to a reserve account set up on its books.
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Petitioner, in 1933, entered into a written agreement with the holder of its bond. The agreement provided that from 1933 on petitioner would set aside from its yearly profits, as a reserve, the sum of $15,624.24 (10 percent of the debt). Until the bond was paid only the yearly profits in excess of the amount to be set aside could be used for the payment of dividends. During each of the years 1936 and 1937 petitioner added $15,624.24 to a reserve account set up on its books. Petitioner at all times had the use and control of the funds in this account, and they were used in its business as…
1Opinion of the Court
L. O. KOVEN & BROTHER, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
L. O. Koven & Bro., Inc. v. Commissioner
Docket No. 108105.
United States Board of Tax Appeals
47 B.T.A. 467; 1942 BTA LEXIS 690;
August 5, 1942, Promulgated
Petitioner, in 1933, entered into a written agreement with the holder of its bond. The agreement provided that from 1933 on petitioner would set aside from its yearly profits, as a reserve, the sum of $15,624.24 (10 percent of the debt). Until the bond was paid only the yearly profits in excess of the amount to be set aside could be used for the payment…
2Cases cited10 opinions
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
- Henry Mill & Timber Co. v. CommissionerUnited States Board of Tax Appeals · 1941
- Honokaa Sugar Co. v. CommissionerUnited States Board of Tax Appeals · 1940
- Thew Shovel Co. v. CommissionerUnited States Board of Tax Appeals · 1941
- Trianon Hotel Co. v. CommissionerUnited States Board of Tax Appeals · 1941
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