Vander Poel, Francis & Co., Inc.

8 T.C. 407 (1947)

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Nature of the Case

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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.