William M. Bailey Company v. Commissioner of Internal Revenue

Third Circuit

William M. Bailey Company v. Commissioner of Internal Revenue

192 F.2d 574, 41 A.F.T.R. (P-H) 390, 1951 U.S. App. LEXIS 3277

CourtCourt of Appeals for the Third Circuit

DecidedNovember 28, 1951

Docket10495_1

StatusPublished

This text of 192 F.2d 574 (William M. Bailey Company v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

William M. Bailey Company v. Commissioner of Internal Revenue, 192 F.2d 574, 41 A.F.T.R. (P-H) 390, 1951 U.S. App. LEXIS 3277 (3d Cir. 1951).

Pincite

Opinion

PER CURIAM.

The sole question raised in this case is whether the taxpayer may deduct, under Section 23(p) (i) (D) of the Internal Revenue Code, 26 U.S.C. § 23(p) (1) (D), amounts which it paid to trustees for insurance premiums under a stock bonus plan creating beneficial interests for a small *575 group of taxpayer’s key employees which were forfeitable as to each of the individual employees in the group. We are satisfied that the amounts so paid are not deductible for the reasons sufficiently stated in the opinion filed in the Tax Court by Judge Opper. 15 T.C. 468.

The decision of the Tax Court will be affirmed.

Free access — add to your briefcase to read the full text and ask questions with AI

PER CURIAM.

The sole question raised in this case is whether the taxpayer may deduct, under Section 23(p) (i) (D) of the Internal Revenue Code, 26 U.S.C. § 23(p) (1) (D), amounts which it paid to trustees for insurance premiums under a stock bonus plan creating beneficial interests for a small *575 group of taxpayer’s key employees which were forfeitable as to each of the individual employees in the group. We are satisfied that the amounts so paid are not deductible for the reasons sufficiently stated in the opinion filed in the Tax Court by Judge Opper. 15 T.C. 468.

The decision of the Tax Court will be affirmed.

Cite This Page — Counsel Stack

Bluebook (online)

192 F.2d 574, 41 A.F.T.R. (P-H) 390, 1951 U.S. App. LEXIS 3277, Counsel Stack Legal Research, https://law.counselstack.com/opinion/william-m-bailey-company-v-commissioner-of-internal-revenue-ca3-1951.

Opinion

Related

Cite This Page — Counsel Stack