Waynesboro Knitting Co. v. Commissioner
United States Tax Court
In 1931, petitioner discovered that one of its officers had embezzled a total of $ 488,010.60 during the years 1926 to 1931. In consideration of the transfer to it by this officer of assets having a total fair market value of $ 258,031.46, petitioner relinquished any further claims which it had against him arising out of his embezzlements.
Read the full summary
In 1931, petitioner discovered that one of its officers had embezzled a total of $ 488,010.60 during the years 1926 to 1931. In consideration of the transfer to it by this officer of assets having a total fair market value of $ 258,031.46, petitioner relinquished any further claims which it had against him arising out of his embezzlements. Petitioner deducted the allocable portions of its net loss of $ 229,979.14 on its returns for 1926 to 1931, but realized tax benefit on only $ 66,326.96 thereof. Among the assets transferred to petitioner in the settlement, were insurance policies on the…
1Opinion of the Court
opinion.
Rige, Judge:
This proceeding involves a deficiency in income tax determined against the Waynesboro Knitting Company (hereinafter referred to as petitioner) in the amount of $9,953.05 for the taxable year 1948.
The sole issue to be decided is whether petitioner derived taxable income in 1948 from the receipt of the proceeds of certain life insurance policies which, among other assets, were transferred to petitioner in 1931 as restitution for the defalcations of one of its officers.
All of the facts were stipulated, are so found, and are incorporated herein by this reference.
Petitioner is…
2Cases cited8 opinions
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Farr v. CommissionerUnited States Tax Court · 1948
- Sloane v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1951
- Birmingham Terminal Co. v. CommissionerUnited States Tax Court · 1951
3 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Continental Illinois Nat'l Bank & Trust Co. v. CommissionerUnited States Tax Court · 1977
- Waynesboro Knitting Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1955
- Smith v. United StatesDistrict Court, D. Maryland · 1965
- Continental Illinois Nat'l Bank & Trust Co. v. CommissionerUnited States Tax Court · 1977
- Waynesboro Knitting Co. v. CommissionerUnited States Tax Court · 1954