Colson Corp. v. Commissioner
United States Tax Court
Respondent may not invoke the provisions of section 711 (b) (1) (J), I. R. C., and disallow a bad debt deduction as an abnormality in computing excess profits net income for the basic period year 1936 where taxpayer has computed its excess profits credit under section 713 (f) and such action will result in a decrease in the taxpayer's excess profits credit.
1Opinion of the Court
OPINION.
Van Fossan, Judge:
The principal issue here presented is whether the respondent may invoke the provisions of section 711 (b) (1) (J) of the Internal Revenue Code so as to disallow a bad debt deduction as an abnormality in computing the petitioner’s excess profits net income for the base period year 1936, where such action will result in an increase in excess profits tax.
The question arises in the computation of the petitioner’s excess profits credit. Section 712 (a) of the code allows an excess profits credit based on income computed under section 713 or on invested capital computed…
Also in this document: Dissent.
2Cases cited4 opinions
- Helvering v. BlissSupreme Court of the United States · 1934
- Bonwit Teller & Co. v. United StatesSupreme Court of the United States · 1931
- William Leveen Corp. v. CommissionerUnited States Tax Court · 1944
- Green Bay Lumber Co. v. CommissionerUnited States Tax Court · 1944
3Cited by17 opinions
- Burke & Herbert Bank & Trust Co. v. CommissionerUnited States Tax Court · 1948
- United States v. William J. HardyCourt of Appeals for the Fourth Circuit · 1962
- Consolidated Motor Lines, Inc. v. CommissionerUnited States Tax Court · 1946
- A. Teichert & Son, Inc. v. CommissionerUnited States Tax Court · 1952
- George J. Meyer Malt & Grain Corp. v. CommissionerUnited States Tax Court · 1948
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