1. Home
  2. Browse Decisions
  3. F.2d
  4. 167 F.2d
  5. 167 F.2d 94 (1948)
 

FRANKEL & SMITH BEAUTY DEPT. v. COMMISSIONER OF INT. REV.

No. 190, Docket 20794.

167 F.2d 94 (1948)

FRANKEL & SMITH BEAUTY DEPARTMENTS, Inc., v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

March 22, 1948.

Attorney(s) appearing for the Case

Saul I. Radin, of New York City, for petitioner.

Theron Lamar Caudle, Sewall Key, George A. Stinson and S. Walter Shine, all of Washington, D. C., for respondent.

Before L. HAND, SWAN and FRANK, Circuit Judges.

FRANK, Circuit Judge.

We have some doubt as to the correctness of taxpayer's basic contention that, for purposes of § 719(a) (1), any unconditional written obligation, contained in a contract, to pay a sum certain is a "note"; but, as the Commissioner does not, at least in this case, take issue with that contention, we shall here accept it arguendo. Even so, we agree with the Tax Court that no "note" exists here.

In the first place, as of the date when...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases