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COMMISSIONER OF INTERNAL REV. v. PATRICK CUDAHY F. CO.

No. 6751.

102 F.2d 930 (1939)

COMMISSIONER OF INTERNAL REVENUE v. PATRICK CUDAHY FAMILY CO.

Circuit Court of Appeals, Seventh Circuit.

March 31, 1939.

Attorney(s) appearing for the Case

James W. Morris, Asst. Atty. Gen., and J. Louis Monarch, W. Croft Jennings, J. P. Wenchel and S. Dee Hanson, Sp. Assts. to Atty. Gen., for petitioner.

Richard H. Tyrrell and Edgar L. Wood, both of Milwaukee, Wis., for respondent.

Before SPARKS, TREANOR, and KERNER, Circuit Judges.

SPARKS, Circuit Judge.

The question here presented is: When, under section 23(c) of the Revenue Act of 1932, 26 U.S.C.A. § 23(c), do personal and real property taxes in the State of Wisconsin accrue as liabilities so as to be deductible from gross income in tax returns made on the accrual basis.

Respondent is a Wisconsin business corporation. It keeps its books on an accrual basis, for a fiscal year ending June 30 of each year. Its income tax return is...

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