Legal Opinion

Polaroid Corp. v. Commissioner

United States Tax Court

Decided November 23, 1959No. Docket No. 65983Published

1. Income from the sale of tangible property resulting from research and development, held, not abnormal within the meaning of section 456(a)(2)(B), I.R.C. 1939. 2. Deductible interest on 1942 and 1943 income tax deficiencies which arose out of excess profits tax relief for same years, held, related to interest credited on excess profits tax refund within the meaning of section 456(a)(3), I.R.C. 1939.

1Opinion of the Court

Polaroid Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Polaroid Corp. v. Commissioner

Docket No. 65983

United States Tax Court

33 T.C. 289; 1959 U.S. Tax Ct. LEXIS 35;

November 23, 1959, Filed

Decision will be entered for the respondent.

1. Income from the sale of tangible property resulting from research and development, held, not abnormal within the meaning of section 456(a)(2)(B), I.R.C. 1939.

2. Deductible interest on 1942 and 1943 income tax deficiencies which arose out of excess profits tax relief for same years, held, related to interest credited on excess profits…

2Cases cited5 opinions

  1. Babcock & Wilcox Co. v. Pedrick. Babcock & Wilcox Tube Co. v. PedrickCourt of Appeals for the Second Circuit · 1954
  2. Ambassador Hotel Co. v. CommissionerUnited States Tax Court · 1959
  3. Morrisdale Coal Mining Co. v. CommissionerUnited States Tax Court · 1953
  4. Big Four Oil & Gas Co. v. CommissionerUnited States Tax Court · 1957
  5. Polaroid Corp. v. CommissionerUnited States Tax Court · 1959

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