Davis Co. v. Commissioner
United States Board of Tax Appeals
1. Only losses sustained within the taxable year are deductible. 2. A sale made in compliance with an insistent request by a local chamber of commerce that a new industry might acquire the desired location, does not constitute an involuntary conversion under section 234(a)(14) of the Revenue Act of 1921.
1Opinion of the Court
*283OPINION.
Milliken :
The first issue questions the correctness of the respondent’s action in adding the reserve for losses and repairs to milk cans to petitioner’s income. The record shows only that such losses were substantial over a period of years and that the amount collected in 1920 for the use of cans was not included in income but was set up as a reserve to cover the losses. Only losses sustained within the taxable year are deductible. Appeal of Hanff-Metzger, Inc., 4 B. T. A. 1214, and cases there cited. As we are unadvised as to the extent of such losses sustained within the taxable…
2Cited by9 opinions
- Descartes v. Tribunal de Contribuciones de Puerto RicoSupreme Court of Puerto Rico · 1953
- Dorothy C. Thorpe Glass Mfg. Corp. v. CommissionerUnited States Tax Court · 1968
- Creative Solutions, Inc. (Formerly Alprodco, Inc.) v. United StatesCourt of Appeals for the Fifth Circuit · 1963
- Hitke v. CommissionerUnited States Tax Court · 1961
- Carson Estate Co. v. CommissionerUnited States Tax Court · 1963
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