SACHS v. COMMISSIONER OF INTERNAL REVENUE

Nos. 11056, 11113.

208 F.2d 313 (1953)

SACHS v. COMMISSIONER OF INTERNAL REVENUE. SLAYMAKER LOCK CO. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Third Circuit.

Decided November 17, 1953.


Attorney(s) appearing for the Case

Herman H. Krekstein, Philadelphia, Pa. (Manuel Kraus, Harrisburg, Pa., Gerald Krekstein, Philadelphia, Pa., on the brief), for petitioner in No. 11056.

Richard S. Doyle, Washington, D. C. (Jules G. Korner, III, Washington, D. C., Eugene C. Fish, Philadelphia, Pa., Blair, Korner, Doyle & Appel, Washington, D. C., on the brief), for petitioner in No. 11113.

Harry Marselli, Washington, D. C. (H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, Robert N. Anderson, Louise Foster, Sp. Assts. to the Atty. Gen., on the brief), for respondent.

Before BIGGS, Chief Judge, and McLAUGHLIN and STALEY, Circuit Judges.


STALEY, Circuit Judge.

These cases were heard separately but present identical questions of law and will be disposed of in one opinion. The facts were not disputed and may be stated very briefly.

Before the close of the taxable year, each taxpayer delivered its negotiable demand note made payable at a bank to the trustee of its exempt employees' pension trust. Although the full amount of each note was paid in cash with interest before the end of the calendar...

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