Poirier & McLane Corp. v. Commissioner
United States Tax Court
Suits were filed against petitioner for damages totaling $ 14,781,150 allegedly resulting from trespass and negligence claimed to have been committed in carrying out two construction jobs. Petitioner contested the claims but, on Dec. 31, 1964, transferred $ 1,100,000 in trust for the sole purpose of the payment of its obligations on the pending claims, taking a deduction for that amount on its 1964 return.
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Suits were filed against petitioner for damages totaling $ 14,781,150 allegedly resulting from trespass and negligence claimed to have been committed in carrying out two construction jobs. Petitioner contested the claims but, on Dec. 31, 1964, transferred $ 1,100,000 in trust for the sole purpose of the payment of its obligations on the pending claims, taking a deduction for that amount on its 1964 return. Judgments ultimately awarded to the claimants were small in amount, eliminating the need for the funds transferred to the trust, and the transferred funds were returned to petitioner. Held,…
1Opinion of the Court
Poirier & McLane Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Poirier & McLane Corp. v. Commissioner
Docket No. 2662-72
United States Tax Court
63 T.C. 570; 1975 U.S. Tax Ct. LEXIS 188;
March 10, 1975, Filed
Decision will be entered under Rule 155.
Suits were filed against petitioner for damages totaling $ 14,781,150 allegedly resulting from trespass and negligence claimed to have been committed in carrying out two construction jobs. Petitioner contested the claims but, on Dec. 31, 1964, transferred $ 1,100,000 in trust for the sole purpose of the payment of its…
Also in this document: Concurrence.
2Cases cited22 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- United States v. Consolidated Edison Co. of NYSupreme Court of the United States · 1961
- City Bank Farmers Trust Co. v. CannonNew York Court of Appeals · 1943
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