Legal Opinion
Wilbur Security Co. v. Commissioner
Court of Appeals for the Ninth Circuit
Decided May 23, 1960No. 16496PublishedCited by 14 opinions
1Opinion of the Court
BARNES, Circuit Judge.
This timely petition for review of a decision of the Tax Court involves deficiencies in corporate taxpayer’s federal income tax for the years 1953, 1954 and 1955, in the amounts of $13,520.46, $17,-254.17 and $17,254.18, respectively. This court has jurisdiction. 26 U.S.C. § 7482.
The sole question is whether the above amounts paid by the taxpayer to certain individuals constituted dividends and not deductible interest.
Concededly, this is a question of fact. The determination of such question of fact by the Tax Court is conclusive on us, unless the conclusion is clearly…
2Cases cited7 opinions
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Gooding Amusement Co. v. CommissionerCourt of Appeals for the Sixth Circuit · 1956
- Matthiessen v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1952
- Earle, Collector of Internal Revenue v. W. J. Jones & Son, Inc. United States v. W. J. Jones & Son, IncCourt of Appeals for the Ninth Circuit · 1952
- Bair v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1952
2 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Lundgren v. FreemanCourt of Appeals for the Ninth Circuit · 1962
- P. M. Finance Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
- Consumers Credit Rural Electric Cooperative Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1963
- Bordo Products Co. v. United StatesUnited States Court of Claims · 1973
- Universal Casting Corp. v. CommissionerUnited States Tax Court · 1961
9 more not listed; retrieve them via the Exa API.