Rice Drug Co. v. Commissioner
United States Tax Court
The petitioner, successor to a partnership, recovered, in 1943 and 1944, upon debts which, prior to January 1, 1940, had been charged off by the partnership and were allowable as deductions from gross income of the partnership. Held, the petitioner may not, under section 711 (a) (1) (E) of the Internal Revenue Code, exclude the recoveries from excess profits taxable income.
1Opinion of the Court
OPINION.
Disney, Judge:
This case involves deficiencies determined in excess profits taxes for the taxable years ended September 30,1943 and 1944, in the amounts of $2,845.85, and $10,320.96, respectively. The single issue presented is whether, under section 711 (a) (1) (E) of the Internal Revenue Code, the petitioner is entitled to exclude from its excess profits net income recoveries made by it in the taxable years on debts for which deduction had been allowable to a partnership from which the petitioner acquired the accounts.
The petitioner submitted the matter upon the pleadings. The…
2Cited by8 opinions
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- Rice Drug Co. v. CommissionerCourt of Appeals for the Third Circuit · 1949
- Merchants Nat'l Bank v. CommissionerUnited States Tax Court · 1950
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