Legal Opinion

Mayfair Minerals, Inc. v. Commissioner

United States Tax Court

Decided April 15, 1971No. Docket No. 5409-68PublishedCited by 55 opinions

For 4 years (1957 through 1960) while contesting an FPC order disapproving a rate increase, petitioner deducted as accrued liabilities the amounts of refunds which it would have been required to make if the FPC order had not been rescinded in a later year (1961). Held, petitioner realized taxable income in the year in which the FPC order was rescinded; petitioner was estopped, because of its conduct, to deny that the deductions of accrued liabilities for the earlier years…

Read the full summary

For 4 years (1957 through 1960) while contesting an FPC order disapproving a rate increase, petitioner deducted as accrued liabilities the amounts of refunds which it would have been required to make if the FPC order had not been rescinded in a later year (1961). Held, petitioner realized taxable income in the year in which the FPC order was rescinded; petitioner was estopped, because of its conduct, to deny that the deductions of accrued liabilities for the earlier years were properly claimed.

1Opinion of the Court

Featherston, Judge:

Respondent determined a deficiency in petitioner’s Federal income tax for its taxable year ending September 80, 1961, in the amount of $785,736.90, and for its taxable year ending September 30, 1963, in the amount of $59,998.63. The only issue presented for decision is whether petitioner realized taxable income in its fiscal year ending September 30, 1961, when it canceled an account payable representing contingent liabilities for customer refunds erroneously deducted as accrued liabilities for its fiscal years ending September 30,1957, through September 30, I960.1

FINDINGS…

2Cases cited41 opinions

  1. Dobson v. CommissionerSupreme Court of the United States · 1944
  2. Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
  3. Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
  4. Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
  5. Commissioner v. WilcoxSupreme Court of the United States · 1946

36 more not listed; retrieve them via the Exa API.

3Cited by55 opinions

  1. Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
  2. Woods v. CommissionerUnited States Tax Court · 1989
  3. Putoma Corp. v. CommissionerUnited States Tax Court · 1976
  4. Mayfair Minerals, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1972
  5. Cluck v. CommissionerUnited States Tax Court · 1995

50 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API