Legal Opinion

Chapin Constr. Co. v. Commissioner

United States Board of Tax Appeals

Decided November 12, 1925No. Docket No. 3200PublishedCited by 1 opinion

A corporation engaged in the business of road and street construction contracting, keeping its accounts on the basis of completed contracts and treating the total contract price as gross income in the year when the original construction work is finished, may not deduct therefrom a reserve for estimated expense of maintenance during the following years specified in the contract. Following Appeal of Uvalde Co.,1 B.T.A. 932.

1Opinion of the Court

*27OPINION.

Teussell:

The Commissioner has filed a plea in bar to the right of the taxpayer to maintain its appeal as to the year 1922 on the ground that there has not been, since the enactment of the Kevenue Act of 1924, a determination by the Commissioner that a deficiency in tax is due from the taxpayer for that year and that the Commissioner has not, since the enactment of the Kevenue Act of 1924, proposed to assess a deficiency in tax against taxpayer for the year 1922. The record discloses that the Commissioner has determined that there is additional tax due from the taxpayer for each of the…

2Cited by1 opinion

  1. Chapin Constr. Co. v. CommissionerUnited States Board of Tax Appeals · 1925

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