Jack's Cookie Company v. The United States of America
Court of Appeals for the Fourth Circuit
1Opinion of the Court
FIELD, Senior Circuit Judge:
On its income tax return for the year ending October 2, 1970, Jack’s Cookie Company (“Jack’s”) claimed a business expense deduction in the amount of $191,720.92 for cash disbursements made during that year under the terms of a written lease for an industrial building. The Internal Revenue Service disallowed $20,479.08 of the deduction, which had the result of reducing taxpayer’s 1970 net operating loss and increasing by $9,829.96 Jack’s tax liability for a prior year to which the 1970 loss had been carried back. Jack’s paid the deficiency for the prior year, plus…
2Cases cited30 opinions
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