Legal Opinion
Don E. Williams Company v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided December 16, 1975No. 74--1812PublishedCited by 16 opinions
1Opinion of the Court
FAIRCHILD, Chief Judge.
Don E. Williams Company appeals from a decision of the Tax Court. The parties stipulated to the facts, set forth in the Tax Court opinion, 62 T.C. 166 (1974). The Tax Court sustained the Commissioner’s disallowance of income tax deductions claimed pursuant to § 404(a) of the Internal Revenue Code of 1954, 26 U.S.C. § 404(a), for contributions to a qualified employee profit-sharing plan.
The issue is whether an accrual taxpayer’s delivery of its secured promissory note to the. trustees of the plan constitutes “payment” within the meaning of § 404(a)(6).
After § 404(a)(3)…
2Cases cited16 opinions
- Eckert v. BurnetSupreme Court of the United States · 1931
- Helvering v. PriceSupreme Court of the United States · 1940
- United States Ex Rel. McLennan v. WilburSupreme Court of the United States · 1931
- Time Oil Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
- Cleaver v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1946
11 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
- Jackson v. CommissionerUnited States Tax Court · 1986
- Solomon v. CommissionerUnited States Tax Court · 1976
- International Telephone & Telegraph Corp. v. United StatesUnited States Court of Claims · 1979
- Patmon, Young & Kirk, Professional Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1976
11 more not listed; retrieve them via the Exa API.