Rockford Varnish Co. v. Commissioner
United States Tax Court
Capital Assets. -- Notes of customers taken on two slow accounts and sold after a number of years were not held primarily for sale to customers in the ordinary course of the taxpayer's business, but were capital assets as defined in section 117 (a) (1).
1Opinion of the Court
OPINION.
MuRdock, Judge:
The Commissioner determined a deficiency of $10,549.28 in excess profits tax for 1943. The only issue for decision is whether a loss of $11,442.48 resulting from the sale of customers’ notes was deductible as an ordinary loss or was a capital loss and of no tax benefit. The facts were stipulated.
The petitioner, an Illinois corporation, filed its return for 1943 with the collector of internal revenue for the first district of Illinois. It used an accrual method of accounting and reporting income.
It was engaged in the business of manufacturing and selling finishing…
2Cited by12 opinions
- Merchants Nat'l Bank v. CommissionerUnited States Tax Court · 1950
- Lehr v. CommissionerUnited States Tax Court · 1952
- George J. Meyer Malt & Grain Corp. v. CommissionerUnited States Tax Court · 1948
- Brubaker v. CommissionerUnited States Tax Court · 1957
- Hilton v. CommissionerUnited States Tax Court · 1949
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