W. J. Byrnes & Co. v. Commissioner
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.
Opinion
[177]*177OPINION.
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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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.