Electrical Fittings Corp. v. Commissioner
United States Tax Court
Petitioner manufactured electrical fittings from metal castings. Several months before the outbreak of hostilities in Korea, it was faced with a shortage of malleable iron castings, the most suitable type for use in its manufacturing business. Castings made from ductile iron, although unsatisfactory in many respects, were the best available substitute.
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Petitioner manufactured electrical fittings from metal castings. Several months before the outbreak of hostilities in Korea, it was faced with a shortage of malleable iron castings, the most suitable type for use in its manufacturing business. Castings made from ductile iron, although unsatisfactory in many respects, were the best available substitute. To insure its supply of ductile iron castings which was also endangered, petitioner in 1951 joined with two other corporations and an individual in organizing a corporation to produce ductile iron castings. Petitioner subscribed and paid for…
1Opinion of the Court
OPINION.
Turner, Judge:
The first issue involves a loss sustained by petitioner on the sale of stock in Ductile, a corporation which produced castings for use in petitioner’s manufacturing business. The respondent has determined that the loss was a capital loss, and disallowed the deduction of the amount from ordinary income.
A supply of iron castings is essential to the petitioner’s business of manufacturing electrical fittings. Several months before the start of the Korean conflict, it became exceedingly difficult for it to obtain malleable iron castings, the most suitable type for electrical…
2Cases cited3 opinions
- Commissioner of Internal Revenue v. The Bagley & Sewall Co.Court of Appeals for the Second Circuit · 1955
- Bagley & Sewall Co. v. CommissionerUnited States Tax Court · 1953
- Smith & Welton, Inc. v. United StatesDistrict Court, E.D. Virginia · 1958
3Cited by45 opinions
- Booth Newspapers, Inc. v. The United States. The Evening News Association v. The United StatesUnited States Court of Claims · 1962
- W. W. Windle Co. v. CommissionerUnited States Tax Court · 1976
- Steadman v. Comm'rUnited States Tax Court · 1968
- Florida Publishing Co. v. CommissionerUnited States Tax Court · 1975
- John J. Grier Co., a Corporation v. United StatesCourt of Appeals for the Seventh Circuit · 1964
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