Kenosha Auto Transport Corp. v. Commissioner
United States Tax Court
Petitioner concedes that for the year 1946 it erroneously deducted from income $ 15,000, which was the credit balance at the end of that year in a reserve account for cargo loss and damage entitled "Insurance Reserve for Loss and Damage," and that for the year 1947 it erroneously deducted from income the net addition to said account of $ 26,994.29. The credit balance in said account on January 1, 1948, was therefore $ 41,994.29, being the total of the two items above…
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Petitioner concedes that for the year 1946 it erroneously deducted from income $ 15,000, which was the credit balance at the end of that year in a reserve account for cargo loss and damage entitled "Insurance Reserve for Loss and Damage," and that for the year 1947 it erroneously deducted from income the net addition to said account of $ 26,994.29. The credit balance in said account on January 1, 1948, was therefore $ 41,994.29, being the total of the two items above referred to. Petitioner also concedes that, for the year 1948, it erroneously deducted from income the amount of $ 110,734.28,…
1Opinion of the Court
Fisher, Judge:
Respondent determined deficiencies in petitioner’s income taxes as follows :
Year Deficiency
1948_$55,964. 82
1949_ 7, 095. 32
The petitioner concedes that of the amount of $237,650.07 deducted as loss and damage expense in 1948, upon the basis of additions to an “Insurance Reserve for Loss or Damage,” $110,734.28 was properly disallowed by the Commissioner.
The petitioner concedes the correctness of the Commissioner’s determination insofar as the taxable year 1949 is concerned.
The question presented is whether petitioner is entitled to deduct as loss and damage expense in the year…
2Cases cited5 opinions
- Commissioner of Internal Revenue v. Mnookin's EstateCourt of Appeals for the Eighth Circuit · 1950
- Mnookin v. CommissionerUnited States Tax Court · 1949
- The Crosley Corporation v. United StatesCourt of Appeals for the Sixth Circuit · 1956
- Comar Oil Co. v. HelveringCourt of Appeals for the Eighth Circuit · 1939
- Waldheim Realty & Inv. Co. v. CommissionerUnited States Tax Court · 1956
3Cited by20 opinions
- Schuster's Express, Inc. v. CommissionerUnited States Tax Court · 1976
- Estate of Hilda Ashman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2000
- North Carolina Granite Corp. v. CommissionerUnited States Tax Court · 1964
- B. C. Cook & Sons, Inc. v. CommissionerUnited States Tax Court · 1972
- Kaufman's, Inc. v. CommissionerUnited States Tax Court · 1957
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