North Star Woolen Mill Co. v. Commissioner
United States Tax Court
Net Operating Loss Deduction Adjustment -- Interest Deduction -- Sec. 711 (a) (2) (L) (i), I. R. C. of 1939. -- No adjustment to the interest deduction is proper in computing the net operating loss of 1947 for which no excess profits credit is computed or allowed.
1Opinion of the Court
OPINION.
MuRDOCk, Judge:
The Commissioner determined a deficiency of $17,880.63 in the excess profits tax of the petitioner for 1945. The only issue for decision is whether one-half of the accrued interest on 1947 indebtedness should be disallowed as a deduction in computing the net operating loss for that year for carry-back purposes. The facts have been presented by a stipulation which is adopted as the findings of fact.
The return for 1945 was filed with the collector of internal revenue for the district of Minnesota. The petitioner was a corporation engaged in the manufacture and sale of…
2Cases cited2 opinions
- Flory Milling Co. v. CommissionerUnited States Tax Court · 1953
- National Fruit Product Co. v. United StatesDistrict Court, W.D. Virginia · 1952
3Cited by7 opinions
- Fahs v. MartinCourt of Appeals for the Fifth Circuit · 1955
- Fahs v. MartinCourt of Appeals for the Fifth Circuit · 1955
- Ambassador Hotel Co. v. CommissionerUnited States Tax Court · 1954
- Ambassador Hotel Co. v. CommissionerUnited States Tax Court · 1954
- Commissioner of Internal Revenue v. North Star Woolen Mill CompanyCourt of Appeals for the Eighth Circuit · 1955
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