Legal Opinion

J. E. Hawes Corp. v. Commissioner

United States Tax Court

Decided August 6, 1965No. Docket No. 5053-63Published

In the taxable year 1960 the petitioner, pursuant to a plan of complete liquidation, sold its notes and accounts receivable at an amount equal to face value less the balance contained in its reserve for bad debts. Held, that upon the cessation in 1960 of the necessity for maintaining the reserve for bad debts, the balance in such reserve constituted ordinary income to the petitioner.

1Opinion of the Court

J. E. Hawes Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

J. E. Hawes Corp. v. Commissioner

Docket No. 5053-63

United States Tax Court

44 T.C. 705; 1965 U.S. Tax Ct. LEXIS 42;

August 6, 1965, Filed

Decision will be entered for the respondent.

In the taxable year 1960 the petitioner, pursuant to a plan of complete liquidation, sold its notes and accounts receivable at an amount equal to face value less the balance contained in its reserve for bad debts. Held, that upon the cessation in 1960 of the necessity for maintaining the reserve for bad debts, the balance in such…

2Cases cited18 opinions

  1. Geyer, Cornell & Newell, Inc. v. CommissionerUnited States Tax Court · 1946
  2. West Seattle National Bank of Seattle v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1961
  3. McClain v. CommissionerSupreme Court of the United States · 1941
  4. West Seattle Nat'l Bank v. CommissionerUnited States Tax Court · 1959
  5. R. Gsell & Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961

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