DON E. WILLIAMS CO. v. COMMISSIONER

No. 75-1312.

429 U.S. 569 (1977)

DON E. WILLIAMS CO. v. COMMISSIONER OF INTERNAL REVENUE.

Supreme Court of United States.

Decided February 22, 1977.


Attorney(s) appearing for the Case

Marvin L. Schrager argued the cause for petitioner. With him on the briefs was Durward J. Long, Sr.

Deputy Solicitor General Jones argued the cause for respondent. On the brief were Solicitor General Bork, Assistant Attorney General Crampton, Stuart A. Smith, Leonard J. Henzke, Jr., and David English Carmack.


MR. JUSTICE BLACKMUN delivered the opinion of the Court.

The issue in this federal income tax case is whether an accrual-basis corporate taxpayer, by delivering its fully secured promissory demand note to the trustees of its qualified employees' profit-sharing trust, is entitled to a deduction therefor under § 404 (a) of the Internal Revenue Code of 1954, 26 U. S. C. § 404 (a).1

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