Producers' Fuel Co. v. Commissioner
United States Board of Tax Appeals
A liability to respond in damages for the breach of a contract occurring in the regular course of the taxpayer's business is a liability incurred at the time of the breach, and an approximately accurate estimate of such damages, set up on the taxpayer's books as a reserve to meet such damages, may be properly claimed as a deduction from gross income for the taxable year within which the breach occurred, although the exact amount required to liquidate such damages may not be…
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A liability to respond in damages for the breach of a contract occurring in the regular course of the taxpayer's business is a liability incurred at the time of the breach, and an approximately accurate estimate of such damages, set up on the taxpayer's books as a reserve to meet such damages, may be properly claimed as a deduction from gross income for the taxable year within which the breach occurred, although the exact amount required to liquidate such damages may not be determined until a later period. When, however, a taxpayer's return is under review by this Board, the amount of a…
1Opinion of the Court
Appeal of PRODUCERS FUEL CO.
Producers' Fuel Co. v. Commissioner
Docket No. 159.
United States Board of Tax Appeals
1 B.T.A. 202; 1924 BTA LEXIS 216;
December 18, 1924, decided Submitted October 31, 1924.
A liability to respond in damages for the breach of a contract occurring in the regular course of the taxpayer's business is a liability incurred at the time of the breach, and an approximately accurate estimate of such damages, set up on the taxpayer's books as a reserve to meet such damages, may be properly claimed as a deduction from gross income for the taxable year within which the breach…
2Cases cited8 opinions
- Roehm v. HorstSupreme Court of the United States · 1900
- United States v. BehanSupreme Court of the United States · 1884
- Hinckley v. Pittsburgh Bessemer Steel Co.Supreme Court of the United States · 1887
- United States v. SpeedSupreme Court of the United States · 1869
- United States v. Purcell Envelope Co.Supreme Court of the United States · 1919
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