Greene Motor Co. v. Commissioner
United States Tax Court
1. Petitioner, on the accrual method of accounting in years prior to 1939, improperly set up certain so-called special reserves and made additions thereto which were claimed and allowed as deductions on its income tax returns for 1938. In 1939 the respondent added the amounts of such reserves as shown on the books as of December 31, 1938, to petitioner's income.
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1. Petitioner, on the accrual method of accounting in years prior to 1939, improperly set up certain so-called special reserves and made additions thereto which were claimed and allowed as deductions on its income tax returns for 1938. In 1939 the respondent added the amounts of such reserves as shown on the books as of December 31, 1938, to petitioner's income. Held, although the so-called reserves set up and the additions thereto claimed and allowed as deductions reduced petitioner's taxable income in those years when allowed, the amounts thereof are not properly includible in petitioner's…
1Opinion of the Court
OPINION.
Disney, Judge:
This controversy involves deficiencies in income tax for the calendar years 1939, 1940, and 1941, and declared value excess profits tax for the calendar years 1939 and 1940, as follows:
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The contested issues are: (1) Whether the respondent properly included in petitioner’s gross income for 1939 balances totaling $3,149.06 on December 31, 1938, in so-called reserves carried on petitioner’s books and never included in petitioner’s taxable income, and (2) whether petitioner is entitled to deduct in 1940 the sum of $1,303.44 disbursed in that year for attorneys’…
2Cases cited7 opinions
- Helvering v. MitchellSupreme Court of the United States · 1938
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Williams v. First Nat. Bank of Pauls ValleySupreme Court of the United States · 1910
2 more not listed; retrieve them via the Exa API.
3Cited by66 opinions
- Commissioner of Internal Revenue v. Mnookin's EstateCourt of Appeals for the Eighth Circuit · 1950
- Mnookin v. CommissionerUnited States Tax Court · 1949
- Commissioner of Internal Revenue v. SchuylerCourt of Appeals for the Second Circuit · 1952
- Lehigh v. R. Co. v. CommissionerUnited States Tax Court · 1949
- Commissioner of Internal Revenue v. James J. Standing and Marie S. StandingCourt of Appeals for the Fourth Circuit · 1958
61 more not listed; retrieve them via the Exa API.