Legal Opinion

Springfield Plywood Corp. v. Commissioner

United States Tax Court

Decided November 24, 1950No. Docket No. 21710Published

Petitioner acquired timberlands and within 6 months thereafter entered into a contract contemplating the disposal of all timber, within certain categories, to be paid for as cut. The contract referred to petitioner as vendor and the other parties as vendees and provided for the cutting of all such timber within 2 years, to be paid for at the end of that time whether cut or not.

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Petitioner acquired timberlands and within 6 months thereafter entered into a contract contemplating the disposal of all timber, within certain categories, to be paid for as cut. The contract referred to petitioner as vendor and the other parties as vendees and provided for the cutting of all such timber within 2 years, to be paid for at the end of that time whether cut or not. Held, that by and at the time of the contract there was "disposal" of the timber within 6 months from acquisition thereof within the language of section 117 (j) (1) and (k) ( 2), Internal Revenue Code, and that…

1Opinion of the Court

Springfield Plywood Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Springfield Plywood Corp. v. Commissioner

Docket No. 21710

United States Tax Court

15 T.C. 697; 1950 U.S. Tax Ct. LEXIS 42;

November 24, 1950, Promulgated

For 1942 deficiency in income tax $ 41.07 and deficiency in excess profits tax $ 18,520.61.

For 1943 deficiency in excess profits tax of $ 7,842.70.

Petitioner acquired timberlands and within 6 months thereafter entered into a contract contemplating the disposal of all timber, within certain categories, to be paid for as cut. The contract referred to…

2Cases cited10 opinions

  1. Phelps v. HarrisSupreme Court of the United States · 1880
  2. United States v. GratiotSupreme Court of the United States · 1840
  3. Rider v. CooneyMontana Supreme Court · 1933
  4. Springfield Plywood Corp. v. CommissionerUnited States Tax Court · 1950
  5. Midland County v. SlaughterCourt of Appeals of Texas · 1910

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