The 1961 National Football League Championship was played on Sunday, December 31, 1961 in Green Bay, Wisconsin between the Green Bay Packers and the New York Giants.
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Arkansas Best, a diversified holding company acquired a large percentage of the stock of the National Bank of Commerce in Dallas, Texas.
The company bought corn futures to protect their future corn supply and pricing and would sell the futures if it had excess inventory corn for its processes.
The Court essentially compared Rockefeller’s past job as Governor of New York with his position as Vice President and found that the two positions did not constitute the same trade or business.
Over the dissenting opinion of four judges, the majority found that the character of the transaction was that of a capital expenditure, and thus not deductible as an Expense.
He was a U.S. Commissioner (i.e. a federal magistrate appointed by the United States District Court for the Eastern District of New York to help with the enforcement of the Volstead Act) until 1931; and a judge of the Queens Municipal Court from 1932 to 1950.
Nor could the payment of taxes of Wood's behalf constitute a gift in the legal sense, because it was made in consideration of his services to the company, thus making it part of his compensation package.