Gulf States Utilities Co. v. Commissioner
United States Tax Court
1. During its base period petitioner made 17 monthly payments of $ 8,000 each in order to operate for a 17-month period under the terms of a new contract rather than under the terms of an old contract with Standard Oil.
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1. During its base period petitioner made 17 monthly payments of $ 8,000 each in order to operate for a 17-month period under the terms of a new contract rather than under the terms of an old contract with Standard Oil. Petitioner claimed the payments as an abnormal deduction as contemplated by section 711 (b) (1) (J), I. R. C.Held, petitioner failed to establish that the abnormality was not a consequence of an increase in its gross income during the base period or a decrease in the amount of some other deduction in its base period and was not a consequence of a change at any time in the…
1Opinion of the Court
OPINION.
Black, Judge:
The three issues presented for our decision have been set forth in our preliminary statement. The first issue concerns expenses of petitioner incurred during 1938 and 1939, while the second issue concerns expenses of petitioner incurred during the year 1939. The taxable years involved are 1942, 1943, 1944, and 1945. Although the Commissioner determined an overassessment in petitioner’s excess profits tax for 1942, we have jurisdiction over that year because petitioner filed claim for relief for that year (Form 843) under section 711 (b) (1) (J) of the Internal Revenue…
2Cases cited7 opinions
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- William Leveen Corp. v. CommissionerUnited States Tax Court · 1944
- Green Bay Lumber Co. v. CommissionerUnited States Tax Court · 1944
- Arrow-Hart & Hegeman Electric Co. v. CommissionerUnited States Tax Court · 1946
- H. E. Harman Coal Corp. v. CommissionerUnited States Tax Court · 1951
2 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Dravo Corporation v. The United StatesUnited States Court of Claims · 1965
- Lutz v. CommissionerUnited States Tax Court · 1966
- Agency of Canadian Car & Foundry Co. v. CommissionerUnited States Tax Court · 1962
- Electric Materials Co. v. CommissionerUnited States Tax Court · 1956
- Japanese Trading Co. v. CommissionerUnited States Tax Court · 1966
6 more not listed; retrieve them via the Exa API.