Logan Engineering Co. v. Commissioner
United States Tax Court
Petitioner, a solvent corporation on an accrual basis of accounting, issued and delivered its promissory notes worth their face amounts to an employees' trust which was tax-exempt under section 165, I. R. C. These notes were paid during the following year. Held, petitioner was not entitled to deduct the amount of the notes in the year of issuance, under section 23 (p), I. R. C.
1Opinion of the Court
OPINION.
Kern, Judge:
The Commissioner determined deficiencies as follows:
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The sole issue presented by the pleadings is whether the issuance and delivery of negotiable, interest-bearing promissory notes by petitioner corporation to an employees’ trust constituted deductible payments within the meaning of section 23 (p) of the Internal Revenue Code.
The facts were stipulated and we incorporate them herein by reference. We refer to only so much of the stipulation as is necessary to a full understanding of our decision.
Petitioner is a corporation, organized under the laws of the State…
2Cases cited4 opinions
- Sioux Tribe of Indians v. United StatesSupreme Court of the United States · 1942
- Anderson v. Pacific Coast Steamship Co.Supreme Court of the United States · 1912
- Spiegel v. CommissionerUnited States Tax Court · 1949
- Akron Welding & Spring Co. v. CommissionerUnited States Tax Court · 1948
3Cited by19 opinions
- Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
- Slaymaker Lock Co. v. CommissionerUnited States Tax Court · 1952
- Don E. Williams Co. v. CommissionerUnited States Tax Court · 1974
- Don E. Williams Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1975
- Wasatch Chemical Co. v. CommissionerUnited States Tax Court · 1962
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