Legal Opinion

Northern States Power Co. v. Commissioner

United States Tax Court

Decided September 25, 1952No. Docket Nos. 29054, 32107, 32106Published

1. Excess Profits -- Abnormal Deductions in Base Period -- Section 711 (b) (1) (J) -- Interest on Late Tax Payments. -- Statutory interest on late tax payments deducted by a public utility in its base period is of a different class of deductions for purposes of section 711 (b) (1) (J) from interest paid and deducted by the utility on its borrowed capital but is not different in class from interest deducted on account of other past due state and Federal tax payments with the…

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1. Excess Profits -- Abnormal Deductions in Base Period -- Section 711 (b) (1) (J) -- Interest on Late Tax Payments. -- Statutory interest on late tax payments deducted by a public utility in its base period is of a different class of deductions for purposes of section 711 (b) (1) (J) from interest paid and deducted by the utility on its borrowed capital but is not different in class from interest deducted on account of other past due state and Federal tax payments with the result that the deduction is not disallowable because abnormal as to class within the meaning of section 711 (b) (1) (J)…

1Opinion of the Court

Northern States Power Company, Petitioner, v. Commissioner of Internal Revenue, Respondent. The Minneapolis General Electric Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Northern States Power Co. v. Commissioner

Docket Nos. 29054, 32107, 32106

United States Tax Court

18 T.C. 1128; 1952 U.S. Tax Ct. LEXIS 94;

September 25, 1952, Promulgated

Decisions will be entered under Rule 50.

1. Excess Profits -- Abnormal Deductions in Base Period -- Section 711 (b) (1) (J) -- Interest on Late Tax Payments. -- Statutory interest on late tax payments deducted by a public utility in its…

2Cases cited2 opinions

  1. Walter Motor Truck Co. v. CommissionerUnited States Tax Court · 1951
  2. Northern States Power Co. v. CommissionerUnited States Tax Court · 1952

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