Legal Opinion

Pennsylvania Electric Steel Casting Co. v. Commissioner

United States Board of Tax Appeals

Decided August 26, 1930No. Docket No. 34934PublishedCited by 6 opinions

In 1924 the petitioner voluntarily, but subject to and with the approval of the Commissioner, changed its accounting period from a fiscal to a calendar year basis.

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In 1924 the petitioner voluntarily, but subject to and with the approval of the Commissioner, changed its accounting period from a fiscal to a calendar year basis. The amount of the net loss sustained by the petitioner for the fiscal year ending August 31, 1923, has been properly allowed as a deduction, in accordance with the provisions of section 206 of the Revenue Act of 1926, in computing the net income for the fiscal year ending August 31, 1924, and in computing the net income for the four-month period ending December 31, 1924. The action of the respondent in refusing to allow as a…

1Opinion of the Court

OPINION.

Matthews:

The petitioner alleges that the respondent, in determining a deficiency of $1,984.52 in income tax for the year 1925, erred in refusing to allow as a deduction in 1925 the sum of $13,416.78, which sum represents the balance of the net loss sustained by- the petitioner for the fiscal year ending August 31, 1923. The. case was submitted upon the following stipulation of facts:

I. Pennsylvania Electric Steel Casting Co. was incorporated December 5, 1922.

2. It originally established its accounting period on a fiscal year basis extending from September 1, 1922, to August 31, 1923.

3.…

2Cited by6 opinions

  1. Campbell-Fairbanks Expositions, Inc. v. United StatesDistrict Court, D. Massachusetts · 1943
  2. Corno Mills Co. v. CommissionerUnited States Board of Tax Appeals · 1930
  3. Pennsylvania Electric Steel Casting Co. v. CommissionerUnited States Board of Tax Appeals · 1930
  4. Prudential Tobacco Co. v. CommissionerUnited States Board of Tax Appeals · 1940
  5. Summerfield Co. v. CommissionerUnited States Board of Tax Appeals · 1931

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