Boston Consol. Gas Co. v. Commissioner
United States Board of Tax Appeals
1. In the taxable year petitioner transferred to profit and loss (surplus) certain amounts representing unclaimed deposits of former customers, and certain amounts representing unclaimed overpayments for gas by former customers, held, the amounts so transferred to surplus were taxable income to petitioner in the year transferred to surplus. 2. Losses from embezzlement of funds are sustained in the year embezzled and are deductible only for that year.
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1. In the taxable year petitioner transferred to profit and loss (surplus) certain amounts representing unclaimed deposits of former customers, and certain amounts representing unclaimed overpayments for gas by former customers, held, the amounts so transferred to surplus were taxable income to petitioner in the year transferred to surplus. 2. Losses from embezzlement of funds are sustained in the year embezzled and are deductible only for that year. Petitioner is entitled to a deduction in the taxable year of only the amount embezzled in that year, reduced by an aliquot part of the…
1Opinion of the Court
BOSTON CONSOLIDATED GAS COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Boston Consol. Gas Co. v. Commissioner
Docket No. 102050.
United States Board of Tax Appeals
44 B.T.A. 793; 1941 BTA LEXIS 1274;
June 24, 1941, Promulgated
1. In the taxable year petitioner transferred to profit and loss (surplus) certain amounts representing unclaimed deposits of former customers, and certain amounts representing unclaimed overpayments for gas by former customers, held, the amounts so transferred to surplus were taxable income to petitioner in the year transferred to surplus.
2. Losses…
2Cases cited6 opinions
- Chicago, Rock Island & Pacific Railway Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- Peterson Linotyping Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- Boston Consol. Gas Co. v. CommissionerUnited States Board of Tax Appeals · 1941
- Grenada Bank v. CommissionerUnited States Board of Tax Appeals · 1935
- Bank of London & South America, Ltd. v. CommissionerUnited States Board of Tax Appeals · 1929
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