Russel Wheel & Foundry Co. v. Commissioner
United States Board of Tax Appeals
1. Where taxpayer claimed certain amounts to be due it from its debtors, the correctness of which claims was disputed by the debtors, and the debtors asserted other claims against taxpayer which were disputed by taxpayer, and taxpayer's claims were bona fide claims for goods sold or money advanced, held that a deductible loss of the difference between the amounts claimed and the amounts realized was sustained in the year in which compromises were effected. 2. Where accounts…
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1. Where taxpayer claimed certain amounts to be due it from its debtors, the correctness of which claims was disputed by the debtors, and the debtors asserted other claims against taxpayer which were disputed by taxpayer, and taxpayer's claims were bona fide claims for goods sold or money advanced, held that a deductible loss of the difference between the amounts claimed and the amounts realized was sustained in the year in which compromises were effected. 2. Where accounts are improperly written off in prior years, they should be restored for the purpose of computing invested capital and…
1Opinion of the Court
*1170OPINION.
Phillips: It appears that in 1912 taxpayer entered into a contract to furnish steel for the erection of a theatre building. The plans for the building were changed, making unavailable for use certain steel fabricated by the taxpayer. Differences arose between the parties and each claimed a violation of the contract by the other. Suits were brought by the Theatre Co. for damages for delay in delivery and by the taxpayer for the amount claimed by it to be due. It appears that a part, at least, of taxpayer’s claim was for steel not actually delivered but prepared for delivery prior to…
2Cited by31 opinions
- Henry Protzmann v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1960
- Whitney Realty Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- A. Garside & Sons v. CommissionerUnited States Board of Tax Appeals · 1930
- Amalgamated Products Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- American Cigar Co. v. CommissionerUnited States Board of Tax Appeals · 1930
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