Legal Opinion
Commissioner of Internal Revenue v. The Bagley & Sewall Co.
Court of Appeals for the Second Circuit
Decided April 21, 1955No. 109, Docket 23096PublishedCited by 65 opinions
1Opinion of the Court
BRENNAN, District Judge.
Whether or not the loss incurred in the posting of U. S. Government bonds as security for the performance of a contract is a capital loss or a business expense is the question posed on this appeal.
A background of essential facts were submitted by stipulation to the Tax Court. The Bagley & Sewall Co. (hereinafter referred to as the taxpayer), is a New York corporation engaged in the manufacture and sale of paper making machinery. In 1946 the taxpayer entered into a contract with a corporation acting in behalf of the Government of Finland for the manufacture and delivery…
2Cases cited12 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Helvering v. HorstSupreme Court of the United States · 1940
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Western Wine & Liquor Co. v. CommissionerUnited States Tax Court · 1952
- Clark v. CommissionerUnited States Tax Court · 1952
7 more not listed; retrieve them via the Exa API.
3Cited by65 opinions
- Enoch v. CommissionerUnited States Tax Court · 1972
- Booth Newspapers, Inc. v. The United States. The Evening News Association v. The United StatesUnited States Court of Claims · 1962
- W. W. Windle Co. v. CommissionerUnited States Tax Court · 1976
- Steadman v. Comm'rUnited States Tax Court · 1968
- E. I. Du Pont De Nemours and Company v. United StatesUnited States Court of Claims · 1961
60 more not listed; retrieve them via the Exa API.