Legal Opinion

West Virginia Steel Corp. v. Commissioner

United States Tax Court

Decided August 15, 1960No. Docket No. 61263PublishedCited by 42 opinions

Held: (1) Additions to a reserve for bad debts in 1951, 1952, and 1953 were in excess of the reasonable needs of petitioner's business; (2) expenditures for new motors for a delivery vehicle and for overhead cranes, as well as for electrical rewiring, were capital in nature; (3) failure to file timely return in 1953 not due to reasonable cause; method for computing addition to tax determined; (4) contribution to profit-sharing trust not accruable in 1953.

1Opinion of the Court

TRAIN, Judge:

The respondent determined deficiencies in income tax and additions to tax in the years and in the amounts as follows:

Addition to Deficiency tax,1 sec. $91 (a) Year

1951-$10, 798. 13 _

1952-7, 528. 41 $4, 020. 73

1953_ 16, 638. 30 _

The issues for decision are:(1) Whether the petitioner claimed deductions as additions to its reserve for bad debts for each of the years 1951, 1952, and 1953, in excess of the reasonable needs of its business;(2) Whether the petitioner erroneously claimed as a deductible expense for 1951, an expenditure to replace a motor in a delivery vehicle;(3) Whether…

2Cases cited5 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. Beck Chemical Equipment Corp. v. CommissionerUnited States Tax Court · 1957
  3. Hornsby v. CommissionerUnited States Board of Tax Appeals · 1932
  4. Bellefontaine Federal Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1960
  5. Tallman Tool & Machine Corp. v. CommissionerUnited States Tax Court · 1956

3Cited by42 opinions

  1. Tomlinson v. LefkowitzCourt of Appeals for the Fifth Circuit · 1964
  2. BJR Corp. v. CommissionerUnited States Tax Court · 1976
  3. Estate of Leyman v. CommissionerUnited States Tax Court · 1963
  4. Cagle v. CommissionerCourt of Appeals for the Fifth Circuit · 1976
  5. Richard L. Smith Vanalco, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2002

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