F. L. Jacobs Co. v. Commissioner
United States Tax Court
Held, in carrying back a 1946 net operating loss to the year 1945 the computation required by section 122 (b) (1) involves the use of the 1944 net income figure after renegotiation and accelerated amortization adjustments and the excess profits tax figure for 1944 before such adjustments.
Read the full summary
Held, in carrying back a 1946 net operating loss to the year 1945 the computation required by section 122 (b) (1) involves the use of the 1944 net income figure after renegotiation and accelerated amortization adjustments and the excess profits tax figure for 1944 before such adjustments. Held, further, the refund or credit in 1947 of a portion of the 1944 excess profits tax due to renegotiation, accelerated amortization, and other adjustments applicable to 1944 does not constitute the receipt of taxable income in 1947 under the "tax benefit" theory.
1Opinion of the Court
F. L. Jacobs Company, Petitioner, v. Commissioner of Internal Revenue, Respondent. F. L. Jacobs Company, Transferee of Parts Manufacturing Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
F. L. Jacobs Co. v. Commissioner
Docket Nos. 56526, 56527, 69983
United States Tax Court
30 T.C. 1194; 1958 U.S. Tax Ct. LEXIS 93;
August 29, 1958, Filed
Decisions will be entered under Rule 50.
Held, in carrying back a 1946 net operating loss to the year 1945 the computation required by section 122 (b) (1) involves the use of the 1944 net income figure after renegotiation and accelerated…
2Cases cited6 opinions
- Lewyt Corp. v. CommissionerSupreme Court of the United States · 1955
- Budd Company v. United StatesCourt of Appeals for the Third Circuit · 1957
- National Forge & Ordnance Company v. United StatesUnited States Court of Claims · 1957
- Continental Foundry & MacHine Co. v. United StatesUnited States Court of Claims · 1958
- F. L. Jacobs Co. v. CommissionerUnited States Tax Court · 1958
1 more not listed; retrieve them via the Exa API.