Legal Opinion

Abkco Industries, Inc. v. Commissioner of Internal Revenue

Court of Appeals for the Third Circuit

Decided August 21, 1973No. 72-1181PublishedCited by 35 opinions

1Opinion of the Court

OPINION OF THE COURT

ALDISERT, Circuit Judge.

This appeal by an accrual basis taxpayer from an adverse decision of the United States Tax Court, 56 T.C. 1083, requires that we decide whether the court erred in disallowing as deductions for business expenses certain liabilities accrued but not actually paid during 1962 and 1963. The Tax Court sustained the contention of the Commissioner of Internal Revenue that certain accrued royalties due an artist under contract to a recording company were contingent liabilities for which no deduction was permissible.

ABKCO Industries, Inc., is engaged in the…

2Cases cited16 opinions

  1. Hormel v. HelveringSupreme Court of the United States · 1941
  2. United States v. AndersonSupreme Court of the United States · 1926
  3. Lucas v. American Code Co.Supreme Court of the United States · 1930
  4. Dobson v. CommissionerSupreme Court of the United States · 1944
  5. Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944

11 more not listed; retrieve them via the Exa API.

3Cited by35 opinions

  1. Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
  2. Universal Electronics Inc. v. United StatesCourt of Appeals for the Federal Circuit · 1997
  3. Lone Manor Farms, Inc. v. CommissionerUnited States Tax Court · 1974
  4. Cluck v. CommissionerUnited States Tax Court · 1995
  5. Sun Oil Company, Transferee, Sunray Dx Oil Company and Subsidiaries, Transferor v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1977

30 more not listed; retrieve them via the Exa API.

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