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
Northwest Casualty Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Northwest Casualty Co. v. Commissioner
Docket No. 37122
United States Tax Court
29 T.C. 573; 1957 U.S. Tax Ct. LEXIS 7;
December 30, 1957, Filed
Decision will be entered for the respondent.
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.
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2Cases cited8 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
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