Beck-Brown Realty Co. v. Commissioner
United States Board of Tax Appeals
1. In 1931 petitioner and another corporation entered into an agreement whereby petitioner was to lend the latter $40,000, in consideration for which the borrower was to pay petitioner a commission of $3,200. Checks for the respective amounts were delivered simultaneously together with a promissory note for $40,000 from the borrower to petitioner. In 1932, the due date of the note was extended for one year in consideration of the payment of an additional commission therefor.
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1. In 1931 petitioner and another corporation entered into an agreement whereby petitioner was to lend the latter $40,000, in consideration for which the borrower was to pay petitioner a commission of $3,200. Checks for the respective amounts were delivered simultaneously together with a promissory note for $40,000 from the borrower to petitioner. In 1932, the due date of the note was extended for one year in consideration of the payment of an additional commission therefor. The amount paid on account of renewal commission in 1932 was not treated as income nor reported as such in petitioner's…
1Opinion of the Court
OPINION.
Hill:
This proceeding is for the redetermination of deficiencies determined by respondent as follows: Income tax for the years 1934 and 1936 in the amounts of $588.08 and $6,309.53, respectively; excess profits tax for the year 1936 in the amount of $245.96; and personal holding company surtax for the years 1934 and 1936 in the amounts of $2,150.57 and $3,268.05, respectively. Respondent also determined a delinquency penalty in the amount of $537.64 for failure to file a personal holding company return for the year 1934 within the time prescribed by law.
Petitioner assigns as error the…
2Cases cited3 opinions
- Higgins v. SmithSupreme Court of the United States · 1940
- Burnet v. Commonwealth Improvement Co.Supreme Court of the United States · 1932
- Dalton v. BowersSupreme Court of the United States · 1932
3Cited by4 opinions
- Trottman v. CommissionerUnited States Tax Court · 1944
- Automotive Bin Serv. Co. v. CommissionerUnited States Tax Court · 1953
- Beck-Brown Realty Co. v. CommissionerUnited States Board of Tax Appeals · 1942
- Kidd v. CommissionerUnited States Tax Court · 1948