Legal Opinion

White Oak Transp. Co. v. Commissioner

United States Board of Tax Appeals

Decided October 9, 1931No. Docket Nos. 18088, 18089, 34945, 34946Published

1. At the close of the year taxpayer had outstanding contracts to purchase coal, which was undelivered. Upon its books, it set up as losses the difference between the contract price and the market price and deducted such alleged losses upon its income-tax returns.

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1. At the close of the year taxpayer had outstanding contracts to purchase coal, which was undelivered. Upon its books, it set up as losses the difference between the contract price and the market price and deducted such alleged losses upon its income-tax returns. Held, that title to such coal not delivered or loaded on cars for shipment to the taxpayer had not passed at the close of the year, that such coal could not be included in inventory, and that no deduction could be taken. 2. A taxpayer corporation should be permitted to include in its inventory as of December 31, 1920, that portion…

1Opinion of the Court

WHITE OAK TRANSPORTATION COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

SEACONNET COAL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

NORTHERN COAL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

C. H. SPRAGUE & SON COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

White Oak Transp. Co. v. Commissioner

Docket Nos. 18088, 18089, 34945, 34946.

United States Board of Tax Appeals

24 B.T.A. 307; 1931 BTA LEXIS 1659;

October 9, 1931, Promulgated

1. At the close of the year taxpayer had outstanding contracts to purchase…

2Cases cited9 opinions

  1. Lucas v. American Code Co.Supreme Court of the United States · 1930
  2. Dentzel v. Island Park Ass'nSupreme Court of Pennsylvania · 1911
  3. Lawson v. HobbsSupreme Court of Virginia · 1917
  4. Stetson & Ellison v. CommissionerUnited States Board of Tax Appeals · 1928
  5. United States Refractories Corp. v. CommissionerUnited States Board of Tax Appeals · 1931

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