Wheeler Insulated Wire Co. v. Commissioner
United States Tax Court
1. Excess Profits Tax -- Net Operating Loss Carry-Back -- Accounting -- Accrual Year. -- A taxpayer using an accrual method of accounting for and reporting its income may not deduct excess profits taxes for 1943 paid in 1944 for the purpose of computing a 1944 net operating loss.
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1. Excess Profits Tax -- Net Operating Loss Carry-Back -- Accounting -- Accrual Year. -- A taxpayer using an accrual method of accounting for and reporting its income may not deduct excess profits taxes for 1943 paid in 1944 for the purpose of computing a 1944 net operating loss. Lewyt Corporation, 18 T. C. 1245, and Hunter Manufacturing Corporation, 21 T. C. 424, followed. 2. Excess Profits Tax -- Credit Carry-Back -- Transfer of Business From One Related Corporation to Another -- Sec. 710 (c), I. R. C. -- A corporation whose profitable business and business assets were taken, in a…
1Opinion of the Court
OPINION.
Muedock, Judge:
The Commissioner determined that the petitioner is liable as transferee of the Wheeler Insulated Wire Company (hereafter called Connecticut) for deficiencies in its tax consisting of $1,761.62 in income tax, $2,491.43 in declared value excess-profits tax, and $25,873.95 in excess profits tax for the taxable year ended August 31,1942, and $3,077.59 in excess profits tax for the taxable year ended August 31, 1943. The issues for decision are whether Connecticut sustained a net operating loss in its fiscal year ended August 31,1944, which may be the basis for a net…
Also in this document: Dissent.
2Cases cited15 opinions
- Weir Long Leaf Lumber Co. v. CommissionerUnited States Tax Court · 1947
- Wier Long Leaf Lumber Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1949
- Rite-Way Products, Inc. v. CommissionerUnited States Tax Court · 1949
- Lewyt Corp. v. CommissionerUnited States Tax Court · 1952
- Gorman Lumber Sales Co. v. CommissionerUnited States Tax Court · 1949
10 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Simon J. Murphy Company and Social Research Foundation, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
- A B C Brewing Corporation (Formerly Aztec Brewing Co.), a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
- Simon J. Murphy Co. v. CommissionerUnited States Tax Court · 1954
- American Well & Prospecting Co. v. CommissionerUnited States Tax Court · 1954
- American Well & Prospecting Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1956
4 more not listed; retrieve them via the Exa API.