Wright & Kremers, Inc. v. United States

LITTLETON, Judge.

The question in this ease is whether a net loss sustained by plaintiff for its first taxable period, July 1 to December 31, 1919’, is deductible from income for the calendar year 1920 under the net loss provisions of section 204 (b) of the Revenue Act of 1918. The Commissioner of Internal Revenue denied the deduction of the 1919 net loss from 1920 income on the ground that plaintiff’s first taxable period of six months after its incorporation was not a “taxable year,” and that, in order for a net loss to be deductible, it must be a loss sustained for a full twelve-month…