Legal Opinion
Lincoln Storage Warehouses v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided July 10, 1950No. 10082_1PublishedCited by 16 opinions
1Opinion of the Court
KALODNER, Circuit Judge.
The question raised on this petition for review is whether Section 24(c) of the Internal Revenue Code, 26 U.S.C.A. § 24(c) 1 precluded the deduction by the taxpayer of amounts credited on its books in 1943 and 1944 as salary, interest and rents to its sole stockholder and, upon his death, to his estate. The issue turns on whether the amounts actually paid are to be applied first to the past indebtedness or first to the current indebtedness of the taxpayer to its sole stockholder and his estate.
The facts which were stipulated and found by the Tax Court 2 accordingly,…
2Cases cited9 opinions
- Anthony P. Miller, Inc. v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1947
- Musselman Hub-Brake Co. v. Com'r of Internal RevenueCourt of Appeals for the Sixth Circuit · 1943
- Grover v. Bd. of Ed., Franklin Twp.New Jersey Court of Chancery · 1928
- Delaware Dredging Co. v. Tucker Stevedoring Co.Court of Appeals for the Third Circuit · 1928
- Lincoln Storage Warehouses v. CommissionerUnited States Tax Court · 1949
4 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Datlof v. United StatesDistrict Court, E.D. Pennsylvania · 1966
- Brown v. CommissionerUnited States Tax Court · 1961
- Chicago & N. W. R. Co. v. CommissionerUnited States Tax Court · 1958
- Burton Swartz Land Corp v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1952
- North American Service Co. v. CommissionerUnited States Tax Court · 1960
11 more not listed; retrieve them via the Exa API.