W. J. Byrnes & Co. v. Commissioner

5 B.T.A. 175, 1926 BTA LEXIS 2932
CourtUnited States Board of Tax Appeals
DecidedOctober 26, 1926
DocketDocket No. 4000.
StatusPublished
Cited by1 cases

This text of 5 B.T.A. 175 (W. J. Byrnes & Co. v. Commissioner) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
W. J. Byrnes & Co. v. Commissioner, 5 B.T.A. 175, 1926 BTA LEXIS 2932 (bta 1926).

Opinion

[177]*177OPINION.

Lansdon :

The petitioner advanced considerable sums for the payment of freight on shipments of goods belonging to its customers. Such advances were generally collected in a short time, but required the use of substantial amounts of capital. Its balance sheets show that at December 31, 1918, it had accounts receivable in the amount of $63,057.39 and accounts payable in the amount of $51,049.48. During the year it operated a warehouse for hire and derived income [178]*178therefrom in the amount of $4,415.83. These facts indicate the use of capital which, though borrowed, was a material income-producing factor.

Judgment will be entered for the Commissioner.

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Related

W. J. Byrnes & Co. v. Commissioner
5 B.T.A. 175 (Board of Tax Appeals, 1926)

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Bluebook (online)
5 B.T.A. 175, 1926 BTA LEXIS 2932, Counsel Stack Legal Research, https://law.counselstack.com/opinion/w-j-byrnes-co-v-commissioner-bta-1926.