Sowers Mfg. Co. v. Commissioner
United States Board of Tax Appeals
Where the petitioner, which keeps its books of account on an accrual basis, has a claim for loss of profits caused by the breach of a contract, accepted and allowed as a general claim by the receiver of an insolvent corporation, recovery of which is uncertain, held that the dividends on said claim should be reported as income for the year in which paid by the receiver.
1Opinion of the Court
*272OPINION.
Green :
The petition alleges and the answer admits that “ the taxes in controversy are income taxes for the calendar years 1922 and 1923, and amount to the sum of $16,492.48.” The respondent has proposed no deficiency for the year 1923. Neither has he rejected an abatement claim for that year. We must, therefore, on our own motion, dismiss the petition for lack of jurisdiction as far as it pertains to the year 1923. Cornelius Cotton Mills, 4 B. T. A. 255.
The question involved in this proceeding is whether the petitioner should report, as taxable income for the year 1922, the allowed…
2Cited by8 opinions
- Ullmann v. CommissionerUnited States Board of Tax Appeals · 1934
- Oregon Terminals Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- American Cigar Co. v. CommissionerUnited States Board of Tax Appeals · 1930
- Oregon Terminals Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Sowers Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1929
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