Anchor Cleaning Service, Inc. v. Commissioner
United States Tax Court
1. Held, accounts acquired by petitioner prior to the taxable years constituted a single capital asset composed of a list of customers; each individual customer's account lost by petitioner during the taxable years was a partial loss of such capital investment and no deduction is allowable therefor. 2. Deductibility in taxable years of increase in New York State franchise tax payable by petitioner by reason hereof, determined.
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1. Held, accounts acquired by petitioner prior to the taxable years constituted a single capital asset composed of a list of customers; each individual customer's account lost by petitioner during the taxable years was a partial loss of such capital investment and no deduction is allowable therefor. 2. Deductibility in taxable years of increase in New York State franchise tax payable by petitioner by reason hereof, determined. Concord Lumber Co., 18 T. C. 843; Curran Realty Co., 15 T. C. 341, followed.
1Opinion of the Court
OPINION.
Van Foss an, Judge:
The primary question here is whether petitioner is entitled to deduct' the losses sustained in the taxable years by reason of the discontinuance by certain of its customers of their general and window cleaning accounts which accounts petitioner had purchased.
According to the pleadings herein, petitioner seeks to establish such deductions as either trade or business expenses under section 23 (a) of the Internal Revenue Code or as losses sustained by a corporation and not compensated for by insurance or otherwise under section 23 (f) thereof.2
The facts found by us on…
2Cases cited7 opinions
- Red Wing Malting Co. v. WillcutsCourt of Appeals for the Eighth Circuit · 1926
- Houston Natural Gas Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1937
- Meredith Pub. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1933
- Metropolitan Laundry Co. v. United StatesDistrict Court, N.D. California · 1951
- Appeal of the Danville Press, Inc.United States Board of Tax Appeals · 1925
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3Cited by39 opinions
- Houston Chronicle Publishing Company, Plaintiff-Appellee-Cross v. United States of America, Defendant-Appellant-CrossCourt of Appeals for the Fifth Circuit · 1973
- Manhattan Co. of Virginia, Inc. v. CommissionerUnited States Tax Court · 1968
- Boe v. CommissionerUnited States Tax Court · 1961
- Westinghouse Broadcasting Co. v. CommissionerUnited States Tax Court · 1961
- Parmelee Transportation Company v. The United StatesUnited States Court of Claims · 1965
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