East Coast Equipment Company v. Commissioner of Internal Revenue

GOODRICH, Circuit Judge.

This appeal from the Tax Court presents two points. One has to do with taxpayer’s tax for 1946 and involves a question under section 44 of the Internal Révenue Code of 1939. The other point affects taxpayer’s tax liability for 1948 and involves a deduction for a bad debt loss. The Tax Court decided against the taxpayer on both points and it appeals. See East Coast Equipment Co. v. Commissioner, 1953, 21 T.C. 112.

I. 1946 Tax.

The 1946 tax turns upon the nature of a transaction by the taxpayer with a con cern called Contractors Acceptance Corporation. The taxpayer is a…