Seas Shipping Co. v. Commissioner
United States Tax Court
1. The petitioner makes its income tax returns upon the calendar year basis in accordance with its books of account. For years prior to 1938 the books of account were kept upon a completed voyage basis and completed lay-up period basis. Under such system all items of income and expense in connection with completed voyages or completed lay-up periods were taken into account in determining the profits or losses of the calendar year.
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1. The petitioner makes its income tax returns upon the calendar year basis in accordance with its books of account. For years prior to 1938 the books of account were kept upon a completed voyage basis and completed lay-up period basis. Under such system all items of income and expense in connection with completed voyages or completed lay-up periods were taken into account in determining the profits or losses of the calendar year. Administrative and general expenses not chargeable to a particular voyage or lay-up period were taken into account in the year of actual payment. The petitioner's…
1Opinion of the Court
OPINION.
Smith, Judge:
The first question for decision is whether the. petitioner is entitled to deduct from its gross income of 1938 $10,491.97 representing the cost of insurance chargeable to voyages completed prior to 1938, and $49,670.40 representing the cost of repairs to the SS Greylock during the months of October and November 1938, which amounts were not paid until January 1939. The respondent has disallowed these deductions upon the ground that the petitioner was on the cash basis for 1938 and that, since the amounts were not disbursed during that year, they are not legal deductions…
2Cases cited4 opinions
- United States v. StewartSupreme Court of the United States · 1940
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
- United States Trust Co. v. HelveringSupreme Court of the United States · 1939
- Superintendent of Five Civilized Tribes v. CommissionerSupreme Court of the United States · 1935
3Cited by9 opinions
- Lykes Bros. Steamship v. United StatesUnited States Court of Claims · 1975
- Pacific Transport Co. v. CommissionerUnited States Tax Court · 1970
- Citizens Federal Sav. & Loan Ass'n v. CommissionerUnited States Tax Court · 1958
- Bien v. CommissionerUnited States Tax Court · 1953
- Bien v. CommissionerUnited States Tax Court · 1953
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