Harris Hardwood Co. v. Commissioner
United States Tax Court
1. Petitioner expended $ 2,765.29 for grading and dirt fill in connection with 1940 flood damage and in erecting a levee to protect its plant from future floods.
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1. Petitioner expended $ 2,765.29 for grading and dirt fill in connection with 1940 flood damage and in erecting a levee to protect its plant from future floods. Held, no part of the expenditure is deductible as an ordinary and necessary business expense of 1941. 2. Held, petitioner has established its right to deduct a casualty loss in 1940 of $ 2,765.29. 3. Dividends under a group life insurance policy, issued in August 1934 and carried by petitioner for the benefit of its employees, were payable and received at the end of each policy year for the first nine years of the policy, except for…
1Opinion of the Court
OPINION.
Arnold, Judge:
The first issue involves an expenditure of $2,765.29 which the respondent capitalized and which petitioner contends is a 1941 expense item. The testimony is specific that the $2,765.29 was charged as an expense item against 1940 income and deducted on petitioner’s 1940 income tax return. Clearly petitioner is not entitled to deduct the expenditure in both taxable years as an expense item. The evidence does not convince us that petitioner is entitled to deduct any part of the $2,765.29 as an expense item chargeable against 1941 income.
The second issue is an alternative to…
2Cases cited4 opinions
- William Leveen Corp. v. CommissionerUnited States Tax Court · 1944
- Arrow-Hart & Hegeman Electric Co. v. CommissionerUnited States Tax Court · 1946
- Premier Products Co. v. CommissionerUnited States Tax Court · 1943
- E. T. Slider, Inc. v. CommissionerUnited States Tax Court · 1945
3Cited by31 opinions
- Ticket Office Equipment Co. v. CommissionerUnited States Tax Court · 1953
- Hunter v. CommissionerUnited States Tax Court · 1966
- E. B. & A. C. Whiting Co. v. CommissionerUnited States Tax Court · 1948
- Primas Groves, Inc. v. CommissionerUnited States Tax Court · 1950
- Mine & Smelter Supply Co. v. CommissionerUnited States Tax Court · 1948
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