Legal Opinion
Talbot Mills v. Commissioner of Internal Revenue
Court of Appeals for the First Circuit
Decided December 22, 1944No. 4015PublishedCited by 16 opinions
1Opinion of the Court
MAHONEY, Circuit Judge.
In its income and excess profits tax returns for the fiscal year ending September 30, 1940, the taxpayer, Talbot Mills, deducted the sum of $40,000 accrued as interest upon certain “registered notes.” The Commissioner of Internal Revenue disallowed the deduction on the ground that it did not represent interest within the meaning of § 23(b) of the Revenue Act of 1938, 52 Stat. 447, 26 U.S.C.A. Internal Revenue Code, § 23(b). The Tax Court of the United States sustained the determination of the Commissioner and concluded “that the ‘registered notes' were more in the…
2Cases cited10 opinions
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Commissioner of Int. Rev. v. Meridian & Thirteenth R. Co.Court of Appeals for the Seventh Circuit · 1942
- Commissioner of Internal Revenue v. Proctor ShopCourt of Appeals for the Ninth Circuit · 1936
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Arthur R. Jones Syndicate v. Commissioner of I. RevenueCourt of Appeals for the Seventh Circuit · 1927
5 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Kraft Foods Company v. Commissioner of Internal Revenue, (Two Cases)Court of Appeals for the Second Circuit · 1956
- J. S. Biritz Construction Co. v. Commissioner of Internal Revenue, Joseph S. Biritz and Dorothy Biritz v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1967
- U. S. Asiatic Co. v. CommissionerUnited States Tax Court · 1958
- Wilbur Security Co. v. CommissionerCourt of Appeals for the Ninth Circuit · 1960
11 more not listed; retrieve them via the Exa API.