Polaroid Corp. v. Commissioner
United States Tax Court
1. Income from the sale of tangible property resulting from research and development, held, not abnormal within the meaning of section 456(a)(2)(B), I.R.C. 1939. 2. Deductible interest on 1942 and 1943 income tax deficiencies which arose out of excess profits tax relief for same years, held, related to interest credited on excess profits tax refund within the meaning of section 456(a)(3), I.R.C. 1939.
1Opinion of the Court
OPINION.
Opper, Judge:
The issues in this case are essentially questions of statutory construction. Respondent does not dispute the facts produced by petitioner.
The income1 which petitioner contends is abnormal under section 456, I.R.C. 1939,2 was earned by the sale of tangible property which arose out of research and development3 extending over a period of more than 12 months. Respondent’s regulations 4 provide that such income is not abnormal and may not constitute a class of income under section 456. This provision in respondent’s regulations is squarely in accord with congressional intent…
2Cases cited4 opinions
- Babcock & Wilcox Co. v. Pedrick. Babcock & Wilcox Tube Co. v. PedrickCourt of Appeals for the Second Circuit · 1954
- Ambassador Hotel Co. v. CommissionerUnited States Tax Court · 1959
- Morrisdale Coal Mining Co. v. CommissionerUnited States Tax Court · 1953
- Big Four Oil & Gas Co. v. CommissionerUnited States Tax Court · 1957
3Cited by1 opinion
- Polaroid Corp. v. CommissionerUnited States Tax Court · 1959