Hecht Co. v. Commissioner
United States Tax Court
Petitioner, having established its eligibility, elected under section 736 (a) of the Internal Revenue Code to compute, for excess profits tax purposes, its income from installment sales on the accrual basis in lieu of the installment basis provided by section 44 (a). During the taxable year ended January 31, 1941, certain installment accounts receivable arising out of sales made prior to February 1, 1940, became worthless and were charged off.
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Petitioner, having established its eligibility, elected under section 736 (a) of the Internal Revenue Code to compute, for excess profits tax purposes, its income from installment sales on the accrual basis in lieu of the installment basis provided by section 44 (a). During the taxable year ended January 31, 1941, certain installment accounts receivable arising out of sales made prior to February 1, 1940, became worthless and were charged off. In addition petitioner incurred collection expenses during the taxable year in connection with collections of installments arising out of pre-1940…
1Opinion of the Court
OPINION.
Arundell, Jvdge:
Petitioner, after becoming eligible and electing under section 736 (a) of the Internal Revenue Code,1 adjusted its excess profits net income for the taxable year ended January 31,1941, to conform to the accrual basis by adding to the figure reported in its original excess profits tax return the net amount ($193,310.18) of unrealized profits on installment sales which had been deferred under the installment method. Respondent’s contention that the figure should be further increased by the amounts of $55,392.45 and $33,211.-22, respectively representing bad debts and…
2Cases cited1 opinion
- Mackin Corp. v. CommissionerUnited States Tax Court · 1946
3Cited by9 opinions
- J. L. Goodman Furniture Co. v. CommissionerUnited States Tax Court · 1948
- Basalt Rock Co. v. CommissionerUnited States Tax Court · 1948
- Commissioner of Internal Revenue v. Hecht Co.Court of Appeals for the Fourth Circuit · 1947
- May, Stern & Co. v. CommissionerUnited States Tax Court · 1946
- Basalt Rock Co. v. CommissionerUnited States Tax Court · 1948
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