William Leveen Corp. v. Commissioner
United States Tax Court
In determining excess profits tax for 1940, abnormal portion of bad debt deduction in a base period year (sec. 711 (b) (1) (J) (ii), I. R. C.), which year also shows an increase in gross income, may not be "disallowed" when evidence fails to show that the abnormality in amount was "not a consequence of an increase in the gross income of the taxpayer in its base period" (sec. 711 (b) (1) (K) (ii)).
1Opinion of the Court
OPINION.
Stbenhagen, Judge:
The taxpayer assails a deficiency of $687.96 in excess profits tax for 1940. Internal Revenue Code, ch. 2, subch. E, part I, sec. 710, et seq. The facts are all stipulated, as follows:
1. The petitioner, for all years pertinent to this proceeding, was a corporation organized under the laws of the State of New Xork. Since its incorporation, on January 2, 1930, the petitioner has been engaged in the business of jobbing woolens.
2. For all years pertinent to this proceeding, the petitioner kept its books and filed its tax returns on an accrual basis, and for taxable…
2Cited by62 opinions
- United States Pipe & Foundry Co. v. PattersonDistrict Court, N.D. Alabama · 1962
- Green Bay Lumber Co. v. CommissionerUnited States Tax Court · 1944
- Surface Combustion Corp. v. CommissionerUnited States Tax Court · 1947
- Denman Tire & Rubber Co. v. CommissionerUnited States Tax Court · 1950
- Harris Hardwood Co. v. CommissionerUnited States Tax Court · 1947
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