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
*204OPINION.
Trussell:
This appeal presents for consideration two questions relating to the application of the Revenue Act of 1918 in determining the total income and profits tax liability of this taxpayer for the calendar years 1919 and 1920. The first question is the amount of net taxable income for the year 1920 and the second the application of the taxpayer for special assessment under the provisions of sections 327 and 328 of said Act for both the years 1919 and 1920.
This taxpayer, during the periods under review, was engaged in the business of a coal broker. In carrying on this business it…
2Cases cited7 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
2 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Harrold v. Commissioner of Internal Revenue. Cromling v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1951
- Dayton Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1937
- General Communication Co. v. CommissionerUnited States Tax Court · 1960
- Eckert Packing Co. v. CommissionerUnited States Board of Tax Appeals · 1940
- Eckstein v. CommissionerUnited States Board of Tax Appeals · 1940
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