Northwest Casualty Co. v. Commissioner
United States Tax Court
1. Petitioner commenced business in 1928 and thereafter in each year, including the base period years, had substantial earnings.
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1. Petitioner commenced business in 1928 and thereafter in each year, including the base period years, had substantial earnings. Held, that its base period net income, computed under section 713 (f), is not an inadequate standard of normal earnings and it does not qualify for relief under section 722 (b) (4), I. R. C. 1939. 2. The deduction by the petitioner, in accordance with its regular method of accounting, of the amounts of reserves for losses, rather than the actual amounts of such losses, as later determined, is not a factor which qualifies it for relief under Code section 722 (b) (5).
1Opinion of the Court
Atkins, Judge:
The respondent disallowed in full the petitioner’s claims for relief from excess profits tax under section 722 of the Internal Revenue Code of 1939 for the calendar years 1942 and 1943. The petitioner seeks a refund of $131,412.30 for the year 1942 and $150,866.18 for the year 1943, representing the entire amounts of excess profits taxes paid for those years.
The petitioner claims that its average base period net income is an inadequate standard of normal earnings by reason of the existence of facts which bring it within the provisions of subsections (b) (4) and (b) (5) of…
2Cases cited7 opinions
- Monarch Cap Screw & Mfg. Co. v. CommissionerUnited States Tax Court · 1945
- A. B. Frank Co. v. CommissionerUnited States Tax Court · 1952
- Clinton Carpet Co. v. CommissionerUnited States Tax Court · 1950
- West Flagler Amusement Co. v. CommissionerUnited States Tax Court · 1954
- Philadelphia, G. & N. R. Co. v. CommissionerUnited States Tax Court · 1946
2 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Northwest Casualty Co. v. CommissionerUnited States Tax Court · 1957