VANDER POEL, FRANCIS & CO., INC.
8 T.C. 407 (1947)
NATURE OF THE CASE: This was a dispute over a cash basis deduction of expenses not paid
as of the tax year.
FACTS: Vander (D) was a cash basis taxpayer. It kept its books and made its income tax
returns on a cash basis. This was a dispute over whether D was entitled to deduct the full
amount of the salaries regularly and duly voted to its two officers when such monies were
unconditionally credited to their respective accounts, notwithstanding the fact that the
salaries in cash or other property were not paid during the tax year. The officers reported
the income on their tax returns under the constructive receipt doctrine. The corporation
deducted them under the constructive payment doctrine.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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