Philadelphia Fire & Marine Ins. Co. v. United States

LITTLETON, Judge.

The computation of the amount of the net loss for 1926 which was allowed by the defendant as a deduction from plaintiff’s income for 1927 was' in accordance with the provisions of section 206 of the Revenue Act of 1926 (26 USCA § 937), and this is not questioned, but plaintiff contends that the entire loss for 1926 of $92,447.31, representing the excess of allowable deductions over its taxable gross income, was deductible from net income for 1927 and that the provisions of section 206 (a) (5) of the 1926 act (26 USCA § 937 (a) (5), which requires that such loss be reduced by…