Colorado Milling & Elevator Co. v. Commissioner
United States Tax Court
1. Excess Profits Tax -- Abnormal Deductions -- Section 711 (b) (1) (J). -- Petitioner, a wheat milling and sales corporation, for the purpose of computing its excess profits credit for the taxable years ended May 31, 1944, and May 31, 1945, reduced its actual opening inventories by use of a formula for each of the base period fiscal years 1938 and 1939, and claimed abnormal deductions therefor under section 711. Held, petitioner's alleged "abnormal deductions" being…
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1. Excess Profits Tax -- Abnormal Deductions -- Section 711 (b) (1) (J). -- Petitioner, a wheat milling and sales corporation, for the purpose of computing its excess profits credit for the taxable years ended May 31, 1944, and May 31, 1945, reduced its actual opening inventories by use of a formula for each of the base period fiscal years 1938 and 1939, and claimed abnormal deductions therefor under section 711. Held, petitioner's alleged "abnormal deductions" being inventory adjustments, are a reduction of cost of goods sold and as such are not within the class of items which are deductions…
1Opinion of the Court
OPINION.
Johnson, Judge:
Petitioner engages in the business of milling and selling wheat, flour, and other wheat products. It has consistently inventoried wheat on the average cost method. In computing the average base period net income it is necessary to ascertain the excess profits net income for each base period year. The excess profits net income for a base period year is determined by starting with the petitioner’s normal tax net income as adjusted for such year and applying against it certain additions and deductions as provided for under section 711, Internal Revenue Code. Of these…
2Cases cited3 opinions
- Arrow-Hart & Hegeman Electric Co. v. CommissionerUnited States Tax Court · 1946
- Universal Optical Co. v. CommissionerUnited States Tax Court · 1948
- George J. Meyer Malt & Grain Corp. v. CommissionerUnited States Tax Court · 1948
3Cited by1 opinion
- Colorado Milling & Elevator Co. v. CommissionerUnited States Tax Court · 1952