Legal Opinion

Frank H. Fleer Corp. v. Commissioner

United States Tax Court

Decided January 30, 1948No. Docket No. 9963Published

1. Abnormality -- Class -- Section 711 (b) (1) (J) (i), I. R. C. -- Excise taxes on chewing gum imposed during part of base period but not during taxable year, held not an abnormal class of deduction. 2. Id. -- A bad debt which resulted, not from transactions with customers or from advances for goods, but from a transaction not directly connected with the business, held abnormal as to class. 3. Abnormality -- Amount -- Section 711 (b) (1) (J) (ii). -- Sales promotion…

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1. Abnormality -- Class -- Section 711 (b) (1) (J) (i), I. R. C. -- Excise taxes on chewing gum imposed during part of base period but not during taxable year, held not an abnormal class of deduction. 2. Id. -- A bad debt which resulted, not from transactions with customers or from advances for goods, but from a transaction not directly connected with the business, held abnormal as to class. 3. Abnormality -- Amount -- Section 711 (b) (1) (J) (ii). -- Sales promotion expenses held not separable in this case from other sales expenses for the purpose of section 711 (b) (1) (J) (ii).

1Opinion of the Court

Frank H. Fleer Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Frank H. Fleer Corp. v. Commissioner

Docket No. 9963

United States Tax Court

10 T.C. 191; 1948 U.S. Tax Ct. LEXIS 276;

January 30, 1948, Promulgated

Decision will be entered under Rule 50.

1. Abnormality -- Class -- Section 711 (b) (1) (J) (i), I. R. C. -- Excise taxes on chewing gum imposed during part of base period but not during taxable year, held not an abnormal class of deduction.

2. Id. -- A bad debt which resulted, not from transactions with customers or from advances for goods, but from a transaction not…

2Cases cited4 opinions

  1. Green Bay Lumber Co. v. CommissionerUnited States Tax Court · 1944
  2. City Auto Stamping Co. v. CommissionerUnited States Tax Court · 1946
  3. Frank Shepard Co. v. CommissionerUnited States Tax Court · 1947
  4. Frank H. Fleer Corp. v. CommissionerUnited States Tax Court · 1948

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