Doug-Long, Inc. v. Commissioner
United States Tax Court
Petitioner owned and operated a truck stop. During the years in issue, petitioner permitted its earnings and profits to accumulate. Held, in applying the Bardahl formula to determine petitioner's working capital needs, petitioner's estimated tax payments are an operating expense. Held, further, petitioner's cash sales, as well as its credit sales, are included in the determination of the duration of petitioner's accounts receivable cycle under the formula.
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Petitioner owned and operated a truck stop. During the years in issue, petitioner permitted its earnings and profits to accumulate. Held, in applying the Bardahl formula to determine petitioner's working capital needs, petitioner's estimated tax payments are an operating expense. Held, further, petitioner's cash sales, as well as its credit sales, are included in the determination of the duration of petitioner's accounts receivable cycle under the formula. Held, further: The amount of accumulations expected or required under the "dividend guidelines" imposed by the Economic Stabilization Act…
1Opinion of the Court
* Doug-Long, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Doug-Long, Inc. v. Commissioner
Docket No. 11051-76
United States Tax Court
72 T.C. 158; 1979 U.S. Tax Ct. LEXIS 134;
April 23, 1979, Filed
Decision will be entered under Rule 155.
Petitioner owned and operated a truck stop. During the years in issue, petitioner permitted its earnings and profits to accumulate. Held, in applying the Bardahl formula to determine petitioner's working capital needs, petitioner's estimated tax payments are an operating expense. Held, further, petitioner's cash sales, as well as its credit…
2Cases cited26 opinions
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- United States v. Donruss Co.Supreme Court of the United States · 1969
- The Smoot Sand & Gravel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
- Dixie, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
- The Smoot Sand & Gravel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957
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