Atlantic C. L. R. Co. v. Commissioner
United States Tax Court
1. Liability under the Fair Labor Standards Act for additional wages to certain of petitioner's employees which was at all times denied and contested until settlement and payment by petitioner in 1940, held, properly accrued as a deduction in 1940, notwithstanding that some of the adjusted payments covered services rendered in 1938 and 1939. 2. Petitioner's consistent method of charging periodic accruals throughout the last half of one taxable year and the first half of the…
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1. Liability under the Fair Labor Standards Act for additional wages to certain of petitioner's employees which was at all times denied and contested until settlement and payment by petitioner in 1940, held, properly accrued as a deduction in 1940, notwithstanding that some of the adjusted payments covered services rendered in 1938 and 1939. 2. Petitioner's consistent method of charging periodic accruals throughout the last half of one taxable year and the first half of the next year, to reflect estimated liability for Federal capital stock tax, held, permissible, and not an improper…
1Opinion of the Court
Opper, Judge:
These consolidated proceedings seek a redetermination of deficiencies in income tax of $14,516.43 and $4,186.58 for 1939 and 1940, respectively.
The primary outstanding issues relate (1) to the proper year of accrual of additional compensation paid in 1940 by petitioner to certain of its employees for services rendered in 1938, 1939, and 1940, under an application of the Fair Labor Standards Act; (2) to the proper accrual year of capital stock tax;'and (3) to petitioner’s claim for a deduction by reason of worthlessness of corporate stock and a bad debt due it.
GENERAL FINDINGS OF…
Also in this document: Dissent.
2Cases cited5 opinions
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- Eckert v. BurnetSupreme Court of the United States · 1931
- First Nat'l Bank v. CommissionerUnited States Tax Court · 1942
- Gray v. New York Nat. Building & Loan Ass'nU.S. Circuit Court for the District of Connecticut · 1903
3Cited by46 opinions
- Geometric Stamping Co. v. CommissionerUnited States Tax Court · 1956
- Baltimore Transfer Co. v. CommissionerUnited States Tax Court · 1947
- Commissioner of Internal Revenue v. Fifth Avenue Coach Lines, Inc., Fifth Avenue Coach Lines, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
- Lehigh v. R. Co. v. CommissionerUnited States Tax Court · 1949
- Fifth Ave. Coach Lines,Inc. v. CommissionerUnited States Tax Court · 1959
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