Legal Opinion

Production Steel, Inc. v. Commissioner

United States Tax Court

Decided September 10, 1979No. Docket No. 2723-77UnpublishedCited by 1 opinion

Petitioner sold goods on an open account to a customer which incurred an operating loss. This loss put the customer in default of its bank line of credit. Termination of this line of credit threatened to stop the customer's operations during a seasonal peak in its operating cycle. A creditors' committee, of which petitioner was a member, was formed which instituted certain changes in the customer's financial organization, thereby avoiding the permanent closing of customer.

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Petitioner sold goods on an open account to a customer which incurred an operating loss. This loss put the customer in default of its bank line of credit. Termination of this line of credit threatened to stop the customer's operations during a seasonal peak in its operating cycle. A creditors' committee, of which petitioner was a member, was formed which instituted certain changes in the customer's financial organization, thereby avoiding the permanent closing of customer. The customer returned to normal operations by the end of December 1971. However, petitioner deducted, as partially…

1Opinion of the Court

PRODUCTION STEEL, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

Production Steel, Inc. v. Commissioner

Docket No. 2723-77.

United States Tax Court

T.C. Memo 1979-361; 1979 Tax Ct. Memo LEXIS 161; 39 T.C.M. (CCH) 77; T.C.M. (RIA) 79361;

September 10, 1979, Filed

Petitioner sold goods on an open account to a customer which incurred an operating loss. This loss put the customer in default of its bank line of credit. Termination of this line of credit threatened to stop the customer's operations during a seasonal peak in its operating cycle. A creditors' committee, of which…

2Cases cited13 opinions

  1. United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
  2. Herbert W. Dustin and Kathleen C. Dustin v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1972
  3. Dustin v. CommissionerUnited States Tax Court · 1969
  4. Riss v. CommissionerUnited States Tax Court · 1971
  5. Trinco Industries, Inc. v. CommissionerUnited States Tax Court · 1954

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

3Cited by1 opinion

  1. Bank of Kirksville v. United StatesDistrict Court, W.D. Missouri · 1996

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