Boston Consol. Gas Co. v. Commissioner
United States Board of Tax Appeals
1. In the taxable year petitioner transferred to profit and loss (surplus) certain amounts representing unclaimed deposits of former customers, and certain amounts representing unclaimed overpayments for gas by former customers, held, the amounts so transferred to surplus were taxable income to petitioner in the year transferred to surplus. 2. Losses from embezzlement of funds are sustained in the year embezzled and are deductible only for that year.
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1. In the taxable year petitioner transferred to profit and loss (surplus) certain amounts representing unclaimed deposits of former customers, and certain amounts representing unclaimed overpayments for gas by former customers, held, the amounts so transferred to surplus were taxable income to petitioner in the year transferred to surplus. 2. Losses from embezzlement of funds are sustained in the year embezzled and are deductible only for that year. Petitioner is entitled to a deduction in the taxable year of only the amount embezzled in that year, reduced by an aliquot part of the…
1Opinion of the Court
*794OPINION.
Black:
The respondent determined a deficiency in income tax against petitioner for the taxable year ended December 31, 1935, in the amount of $32,242.13. The petitioner brings this proceeding for a redetermination of his tax liability for that year. The respondent admitted at the hearing that petitioner was entitled to an additional deduction of $517.42 representing electrical energy tax which accrued in 1935. Certain other adjustments made by the Commissioner in his determination of the deficiency are not contested.
In its petition the petitioner alleges that the taxes in controversy…
2Cited by8 opinions
- Ramsay Scarlett & Co. v. CommissionerUnited States Tax Court · 1974
- Boston Consol. Gas Co. v. Commissioner of Internal Rev.Court of Appeals for the First Circuit · 1942
- Policy Holders Agency, Inc. v. CommissionerUnited States Tax Court · 1963
- Growers Credit Corp. v. CommissionerUnited States Tax Court · 1960
- Boston Consol. Gas Co. v. CommissionerUnited States Board of Tax Appeals · 1941
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