Alabama-Georgia Syrup Co. v. Commissioner
United States Tax Court
1. Brokerage commissions paid to sister of petitioner L. B. Whitfield (Louis) by suppliers of raw materials to petitioner Alabama-Georgia Syrup Company (Alaga) do not constitute income to Alaga or represent payment of dividends or interest by Alaga to Katherine. 2. Legal fees paid by Alaga and petitioner W. & W. Pickle and Canning Company (W. & W.) to their general counsel were not paid for the benefit of the estate of L. B. Whitfield, Sr. (Whitfield's estate), but are…
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1. Brokerage commissions paid to sister of petitioner L. B. Whitfield (Louis) by suppliers of raw materials to petitioner Alabama-Georgia Syrup Company (Alaga) do not constitute income to Alaga or represent payment of dividends or interest by Alaga to Katherine. 2. Legal fees paid by Alaga and petitioner W. & W. Pickle and Canning Company (W. & W.) to their general counsel were not paid for the benefit of the estate of L. B. Whitfield, Sr. (Whitfield's estate), but are ordinary and necessary business expenses of Alaga and W. & W., deductible by these corporations, and no part of such amount…
1Opinion of the Court
Scott, Judge:
Respondent determined deficiencies in income tax of the petitioners for the years and in the amounts as follows:
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Although, respondent determined no deficiency against Alabama-Georgia Syrup Company for its fiscal year ended September 30,1956, or against W. & W. Pickle and Canning Company for its fiscal year ended March 31, 1957, these fiscal years of the respective petitioners are involved herein because of claimed loss carrybacks to the fiscal years 1954 and 1955, respectively.
The issues for decision are:
With respect to petitioner Alabama-Georgia Syrup Company: (1)…
2Cases cited16 opinions
- Baird v. CommissionerUnited States Tax Court · 1955
- Wiese v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1938
- Heman v. CommissionerUnited States Tax Court · 1959
- Wiese v. CommissionerUnited States Board of Tax Appeals · 1937
- Silverman v. CommissionerUnited States Tax Court · 1957
11 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Local Finance Corp. v. CommissionerUnited States Tax Court · 1967
- La Croix v. CommissionerUnited States Tax Court · 1974
- L. B. Whitfield, Jr., and Virginia G. Whitfield v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1962
- United States v. Roy O. Disney and Edna F. DisneyCourt of Appeals for the Ninth Circuit · 1969
- Kingsford Co. v. CommissionerUnited States Tax Court · 1964
17 more not listed; retrieve them via the Exa API.