Carithers-Wallace-Courtenay v. Commissioner
United States Tax Court
Petitioner seeks to invoke application of section 734 of the Internal Revenue Code to adjust excess profits credit in determining excess profits tax liability for the taxable year 1942 because of claimed inconsistency of treatment in disallowing a deduction for addition to reserve for bad debts in that year and in not disallowing a deduction of like character in the prior year of 1939. Held, the facts of record are insufficient to establish inconsistency of treatment…
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Petitioner seeks to invoke application of section 734 of the Internal Revenue Code to adjust excess profits credit in determining excess profits tax liability for the taxable year 1942 because of claimed inconsistency of treatment in disallowing a deduction for addition to reserve for bad debts in that year and in not disallowing a deduction of like character in the prior year of 1939. Held, the facts of record are insufficient to establish inconsistency of treatment necessary to the application of section 734.
1Opinion of the Court
OPINION.
Hill, Judge-.
The Commissioner determined deficiencies as follows:
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The deficiencies determined for the fiscal years ended June 30, 1940 and 1941, are no longer contested by the petitioner and have been paid. Petitioner seeks adjustment of its excess profits tax liability under the provisions of section 734 of the Internal Revenue Code.
The petitioner is a Georgia corporation, having its principal place of business at Atlanta, Georgia. It filed its income tax returns for the fiscal years ended June 30, 1940, 1941, and 1942, with the collector of internal revenue at Atlanta,…
2Cited by18 opinions
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- Massachusetts Business Development Corp. v. CommissionerUnited States Tax Court · 1969
- Rosemary Mfg. Co. v. CommissionerUnited States Tax Court · 1947
- Bulova Watch Co. v. United StatesUnited States Court of Claims · 1958
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