Legal Opinion
International F. Corp. v. Commissioner of Int. Rev.
Court of Appeals for the Second Circuit
Decided March 6, 1943No. 5PublishedCited by 24 opinions
1Opinion of the Court
FRANK, Circuit Judge.
1. Up to the time in 1936 when the shares were delivered to the employees, the taxpayer retained such control of the shares that title had not passed to the employees. We think the Tax Court correctly held that the market value at the time of delivery was properly deducted by the taxpayer as an ordinary expense of the business under Revenue Act 1936, § 23(a), 26 U.S.C.A. Int.Rev.Code § 23(a), because that delivery was an additional reasonable compensation for past services actually rendered. Cf. Lucas v. Ox Fibre Brush Co., 281 U.S. 115, 50 S.Ct. 273, 74 L.Ed. 733. The…
2Cases cited8 opinions
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Lucas v. Ox Fibre Brush Co.Supreme Court of the United States · 1930
- General Utilities & Operating Co. v. HelveringSupreme Court of the United States · 1935
- Fisher v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1932
- Commissioner of Internal Revenue v. MestaCourt of Appeals for the Third Circuit · 1941
3 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- United States v. DavisSupreme Court of the United States · 1962
- United States v. General Shoe CorporationCourt of Appeals for the Sixth Circuit · 1960
- Andrews v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1943
- Seas Shipping Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- Donald A. Jackson, Jr. And Marilynn Jackson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
19 more not listed; retrieve them via the Exa API.