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Don E. Williams Co. Vs. Commissioner
Cites for this judgment
- US Supreme Court
- Feb 22, 1977
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U.S. 569 (1977) U.S. Supreme Court Don E. Williams Co. v. CommissionerSearch
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U.S. 569 (1977) Don E. Williams Co. v. CommissionerSearch
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Commissioner v. NationalSearch
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Page 429 U. S. 577 administrative construction may be said to have received congressional approval. See Lykes v. UnitedSearch
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decisions of this Court, although they concern cost basis taxpayers, are of helpful significance. The first is Eckert v. BurnetSearch
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Id. at 283 U. S. 141 . The second decision is Helvering v. PriceSearch
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Hart v. CommissionerSearch
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pay. It does not, in itself, constitute an outlay of cash or other property. A similar argument was made in Helvering v. PriceSearch
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Alfalfa Dehydrating, 417 U. S. 134 , 417 U. S. 148 -149 (1974). See Central Tablet Mfg. Co. v. UnitedSearch
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a) derives from two earlier cases, namely, Anthony P. Miller, Inc. v. CommissionerSearch
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F.2d 268 (CA3 1947), cert. denied, 333 U.S. 861 (1948), and Musselman Hub-Brake Co. v. CommissionerSearch
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Logan Engineering Co. v. CommissionerSearch
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of exchange, and has come to be treated for federal tax purposes as a conditional payment of cash. Estate of Spiegel v. CommissionerSearch
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a). Tr. of Oral Arg. 28-31. See Dick Bros. v. CommissionerSearch
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Slaymaker Lock Co. v. CommissionerSearch
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T.C. 1001 (1952) (Bruce, J.), rev'd sub nom. Sachs v. CommissionerSearch
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Time Oil Co. v. CommissionerSearch
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Wasatch Chemical Co. v. CommissionerSearch
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dissents), remanded, 313 F.2d 843 (CA10 1963). Memorandum decisions to the same effect are Freer Motor Transfer v. CommissionerSearch
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Sachs v. CommissionerSearch
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Lancer Clothing Corp. v. CommissionerSearch
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Coastal Electric Corp. v. CommissionerSearch
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Rev.Rul. 55-608, 1952 Cum.Bull. 546, 548. See also Patmon, Young & Kirk v. CommissionerSearch
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F.2d 843 (CA10 1963) (unsecured interest-bearing five-year promissory notes). Accord, Advance Constr. Co. v. UnitedSearch
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The persistence of the Government in pursuing its position on an issue of tax law has been noted before. United States v. FosterSearch
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Other courts have applied Eckert and Price to situations other than a claimed bad debt deduction. Cleaver v. CommissionerSearch
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Jenkins v. BitgoodSearch
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Baltimore Dairy Lunch, Inc. v. UnitedSearch
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Guren v. CommissionerSearch
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Petty v. CommissionerSearch
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Celina Mfg. Co. v. CommissionerSearch
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Commissioner v. MundetSearch
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Akron Welding & Spring Co. v. CommissionerSearch
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today's decision, for only by treating the petitioner as a cash method taxpayer can the Court apply the rule of Eckert v. BurnetSearch
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U. S. 140 , and Helvering v. PriceSearch
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taxpayers should not be lumped together when applying statutes such as this one. The case of Musselman Hub-Brake Co. v. CommissionerSearch
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Anthony P. Miller, Inc. v. CommissionerSearch
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Advance Constr. Co. v. UnitedSearch
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States, 356 F.Supp. 1267 (ND Ill.). See also Hart v. CommissionerSearch
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U.S. Supreme Court Don E. Williams Co. v. CommissionerSearch
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See Lykes v. UnitedSearch
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Helvering v. PriceSearch
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See Central Tablet Mfg. Co. v. UnitedSearch
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and Musselman Hub-Brake Co. v. CommissionerSearch
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See Dick Bros. v. CommissionerSearch
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Freer Motor Transfer v. CommissionerSearch
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Patmon, Young & Kirk v. CommissionerSearch
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