GARLAND

v.

UNITED STATES

Citator

Cited By

• Don E. Williams Co. v. Commissioner of Internal Revenue, 429 U.S. 569 (U.S. 1977)
  …re accrued but not yet paid to related cash-basis payees. The analogy the Courts of Appeals drew between § 404 (a) and § 267 (a) derives from two earlier cases, namely, Anthony P. Miller, Inc. v. Commissioner, 164 F. 2d 268 (CA3 1947), cert. denied, 333 U. S. 861 (1948), and Musselman Hub-Brake Co. v. Commissioner, 139 F. 2d 65 (CA6 1943), where it was ruled that an accrual-basis corporate taxpayer’s delivery of a demand note to one of its officers for salary or to its controlling shareholder for royalties a…
• People OF the State OF NEW York v. Galamison, 342 F.2d 255 (2d Cir. 1965)
  …tate not to interfere with them and thereby protects that activity, see Niemotko v. State of Maryland, 340 U.S. 268, 272, 71 S.Ct. 325, 95 L.Ed. 267 (1951) ; cf. Steele v. Superior Court of California, 164 F. 2d 781, 782 (9 Cir. 1947), cert. denied, 333 U.S. 861, 68 S.Ct. 739, 92 L.Ed. 1140 (1948), and Hill v. Com. of Pennsylvania, 183 F.Supp. 126 (W.D.Pa. 1960), both suggesting that there would be removal (though not specifying whether it would be under subdivision 1 or 2 of § 1443) if the arrest or prosec…

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• Sachs v. Commissioner of Internal Revenue, 208 F.2d 313 (3d Cir. 1953)
  …cases. As to the lavs, there are no four-square •cases in the courts of appeals, but there •are some rather persuasive analogies. In Anthony P. Miller, Inc. v. Commissioner of Internal Revenue, 3 Cir., 1947, 164 F. 2d 268, certiorari denied, 1948, 333 U.S. 861, we held that the taxpayer had '“paid” its president’s salary by delivery to him of its negotiable demand notes within two and one-half months after the close of its taxable year and, therefore, was entitled to deduct the face amount of the notes fr…