Foundation Co. v. Commissioner
United States Tax Court
Issue 1. Upon the facts, held, the respondent correctly disallowed deduction in 1940 of an alleged expense. Issue 2. Petitioner entered into a contract with a Peruvian corporation under which the consideration was to be paid in soles. The corporation defaulted in payments, which gave rise to a debt. The value of soles declined after the debt accrued. Petitioner reported income on the accrual basis.
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Issue 1. Upon the facts, held, the respondent correctly disallowed deduction in 1940 of an alleged expense. Issue 2. Petitioner entered into a contract with a Peruvian corporation under which the consideration was to be paid in soles. The corporation defaulted in payments, which gave rise to a debt. The value of soles declined after the debt accrued. Petitioner reported income on the accrual basis. Held, upon the facts, that petitioner sustained losses upon the conversion of the depreciated soles which it received in payment of the debt. B. F. Goodrich, 1 T. C. 1098, distinguished; held,…
1Opinion of the Court
HarRon, Judge:
Respondent determined a deficiency in petitioner’s income tax for the calendar year 1942 in the amount of $151,506.73. This deficiency results principally from respondent’s disallowance of alleged net operating loss carry-overs' from 1940 and 1941 and an alleged net operating loss carry-back from 1943. Petitioner contests this disallowance, but does not contest certain other adjustments to its net income for 1942 made in the notice of deficiency. Petitioner claims that it has made overpayment of tax and is entitled to a refund.
The parties have stipulated that the petitioner…
2Cases cited9 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Boehm v. CommissionerSupreme Court of the United States · 1945
- Lewellyn v. Electric Reduction Co.Supreme Court of the United States · 1927
- Heiner v. MellonSupreme Court of the United States · 1938
4 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Marko Durovic v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1973
- Ramsay Scarlett & Co. v. CommissionerUnited States Tax Court · 1974
- Columbian Rope Co. v. CommissionerUnited States Tax Court · 1964
- American Air Filter Co. v. CommissionerUnited States Tax Court · 1983
- National-Standard Co. v. CommissionerUnited States Tax Court · 1983
24 more not listed; retrieve them via the Exa API.