Schneider Grocery Co. v. Commissioner
United States Tax Court
A deduction claimed by and allowed to the petitioner in its 1937 return as a casualty loss from flood, held, properly disallowed by the respondent under section 711 (b) (1) (E) in determining petitioner's average base period net income for the purpose of computing excess profits tax for 1943 and 1944.
1Opinion of the Court
OPINION.
LeMire, Judge:
We think that the Commissioner’s disallowance of the amount in question in computing the petitioner’s excess profits credit was in accordance with the statute. Section 711 (b) (1) (E) provides that in computing the base period excess profits income “Deductions under section 23 (f) * * * shall not be allowed.” The petitioner does not deny that it claimed the deduction of the amount of $14,740.28 in its 1937 return under section 23 (f), or that the deduction was allowed, but it contends that all or a part of such amount represented ordinary and necessary expenses which are…
2Cases cited1 opinion
- Consolidated Motor Lines, Inc. v. CommissionerUnited States Tax Court · 1946
3Cited by5 opinions
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- Schneider Grocery Co. v. CommissionerUnited States Tax Court · 1948