Chicago Warehouse Lumber Co. v. Commissioner

Board of Tax Appeals

Chicago Warehouse Lumber Co. v. Commissioner

16 B.T.A. 1416, 1929 BTA LEXIS 2386

United States Board of Tax Appeals·Decided July 24, 1929·No. Docket No. 21427.·Published·Cited by 1 cases

Opinion

[1418] OPINION.

Siefkin :

The petitioner, in order to justify the deduction of $4,800 in 1922, relies upon an oral agreement or understanding in 1922 that such action would be taken. It is clear, however, that corporate ación was not taken until 1923 and, consequently, no liability to pay accrued to the petitioner until that year. See Edward S. Jones et al., 6 B. T. A. 1048. It follows that the action of the respondent in disallowing the deduction in 1922 must be approved.

Judgment will be entered for the respondent.

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[1418] OPINION.

Siefkin :

The petitioner, in order to justify the deduction of $4,800 in 1922, relies upon an oral agreement or understanding in 1922 that such action would be taken. It is clear, however, that corporate ación was not taken until 1923 and, consequently, no liability to pay accrued to the petitioner until that year. See Edward S. Jones et al., 6 B. T. A. 1048. It follows that the action of the respondent in disallowing the deduction in 1922 must be approved.

Judgment will be entered for the respondent.

Chicago Warehouse Lumber Co. v. Commissioner, 16 B.T.A. 1416, 1929 BTA LEXIS 2386 (bta 1929).

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Opinion

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