Legal Opinion

Lehman Co. of America, Inc. v. Commissioner

United States Tax Court

Decided September 26, 1951No. Docket No. 21839Published

1. Petitioner is entitled to allocate insurance proceeds received in the taxable year ended January 31, 1947, from the destruction by fire of certain of its properties, between the capital and noncapital assets destroyed, and the amount allocable to each such class of property is determined. 2. Petitioner is entitled to a deduction of the amount of $ 2,349 in the taxable year ended January 31, 1947, representing a contribution to the Cannelton Flood Wall Fund. 3. Petitioner…

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1. Petitioner is entitled to allocate insurance proceeds received in the taxable year ended January 31, 1947, from the destruction by fire of certain of its properties, between the capital and noncapital assets destroyed, and the amount allocable to each such class of property is determined. 2. Petitioner is entitled to a deduction of the amount of $ 2,349 in the taxable year ended January 31, 1947, representing a contribution to the Cannelton Flood Wall Fund. 3. Petitioner is entitled to an excess profits tax credit carry-back to the fiscal year ended January 31, 1945, in an amount to be…

1Opinion of the Court

The Lehman Company of America, Incorporated, Petitioner, v. Commissioner of Internal Revenue, Respondent

Lehman Co. of America, Inc. v. Commissioner

Docket No. 21839

United States Tax Court

17 T.C. 422; 1951 U.S. Tax Ct. LEXIS 84;

September 26, 1951, Promulgated

Decision will be entered under Rule 50.

1. Petitioner is entitled to allocate insurance proceeds received in the taxable year ended January 31, 1947, from the destruction by fire of certain of its properties, between the capital and noncapital assets destroyed, and the amount allocable to each such class of property is determined.

2.…

2Cases cited4 opinions

  1. Watson v. CommissionerUnited States Tax Court · 1950
  2. McCoy v. CommissionerUnited States Tax Court · 1950
  3. Battle Creek Food Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1950
  4. Lehman Co. of America, Inc. v. CommissionerUnited States Tax Court · 1951

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