McKay Machine Co. v. Commissioner
United States Tax Court
Excess Profits Tax Credit. -- An inventory adjustment at the close of 1949 to reflect a reduction from cost to recoverable value of component parts of a mill produced by the petitioner, which it was unable to deliver because of inability to procure an export license, is not a deduction as contemplated by section 23 of the Internal Revenue Code of 1939 and is therefore not a disallowable abnormal deduction under section 433 (b) (9) for the purpose of computing the excess…
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Excess Profits Tax Credit. -- An inventory adjustment at the close of 1949 to reflect a reduction from cost to recoverable value of component parts of a mill produced by the petitioner, which it was unable to deliver because of inability to procure an export license, is not a deduction as contemplated by section 23 of the Internal Revenue Code of 1939 and is therefore not a disallowable abnormal deduction under section 433 (b) (9) for the purpose of computing the excess profits tax credit, based on income, for the year 1950.
1Opinion of the Court
Atkins, Judge:
The respondent determined a deficiency in the petitioner’s income tax for the calendar year 1950 in the amount of $8,309.89. The primary issue is whether in computing the petitioner’s excess profits credit tlie petitioner is entitled to increase its base period net income by restoring to income for the year 1949 the amount of an inventory adjustment which the petitioner had taken with respect to certain machinery which the petitioner had produced under contract.
FINDINGS OP PACT.
The petitioner is an Ohio corporation with principal office in Youngstown, Ohio. Its Federal income…
2Cases cited7 opinions
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
- Green Bay Lumber Co. v. CommissionerUnited States Tax Court · 1944
- Arrow-Hart & Hegeman Electric Co. v. CommissionerUnited States Tax Court · 1946
- Universal Optical Co. v. CommissionerUnited States Tax Court · 1948
- Mine & Smelter Supply Co. v. CommissionerUnited States Tax Court · 1948
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3Cited by11 opinions
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- Space Controls, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1963
- National Biscuit Co. v. CommissionerUnited States Tax Court · 1957
- Thompson-Hayward Chemical Co. v. CommissionerUnited States Tax Court · 1958
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