Legal Opinion

Walter Motor Truck Co. v. Commissioner

United States Tax Court

Decided March 28, 1951No. Docket No. 23041Published

Petitioner accrued and deducted from its income for the year ended June 30, 1940, interest of $ 8,627.03 paid on a Federal income tax deficiency. In computing its excess profits credit for the fiscal year ended June 30, 1945, petitioner restored $ 8,175.60 of that interest payment to its income for fiscal 1940 under the provisions of section 711 (b) (1) (J) (ii), Internal Revenue Code.

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Petitioner accrued and deducted from its income for the year ended June 30, 1940, interest of $ 8,627.03 paid on a Federal income tax deficiency. In computing its excess profits credit for the fiscal year ended June 30, 1945, petitioner restored $ 8,175.60 of that interest payment to its income for fiscal 1940 under the provisions of section 711 (b) (1) (J) (ii), Internal Revenue Code. Held, because of the limiting provisions of section 711 (b) (1) (K) (iii), petitioner may not restore any part of that interest payment to income for fiscal 1940 because it was of the same class of deduction…

1Opinion of the Court

Walter Motor Truck Co., Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Walter Motor Truck Co. v. Commissioner

Docket No. 23041

United States Tax Court

16 T.C. 645; 1951 U.S. Tax Ct. LEXIS 245;

March 28, 1951, Promulgated

Decision will be entered under Rule 50.

Petitioner accrued and deducted from its income for the year ended June 30, 1940, interest of $ 8,627.03 paid on a Federal income tax deficiency. In computing its excess profits credit for the fiscal year ended June 30, 1945, petitioner restored $ 8,175.60 of that interest payment to its income for fiscal 1940 under the…

2Cases cited3 opinions

  1. Arrow-Hart & Hegeman Electric Co. v. CommissionerUnited States Tax Court · 1946
  2. Frank Shepard Co. v. CommissionerUnited States Tax Court · 1947
  3. Walter Motor Truck Co. v. CommissionerUnited States Tax Court · 1951

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