Great American Indem. Co. v. Commissioner
United States Tax Court
1. Excess Profits Tax -- Abnormal Deduction -- Surety Loss -- Class -- Section 711 (b) (1) (J) (i) and (ii). -- A deduction taken in 1939 for an anticipated loss on a surety bond was not a separate class and abnormal within section 711 (b) (1) (J) (i) and the surety code number under which it was classified did not represent a class of deductions for the purpose of section 711 (b) (1) (J) (ii). 2. Excess Profits Tax -- Exclusion of Income of Taxable Year -- Section 711 (a)…
Read the full summary
1. Excess Profits Tax -- Abnormal Deduction -- Surety Loss -- Class -- Section 711 (b) (1) (J) (i) and (ii). -- A deduction taken in 1939 for an anticipated loss on a surety bond was not a separate class and abnormal within section 711 (b) (1) (J) (i) and the surety code number under which it was classified did not represent a class of deductions for the purpose of section 711 (b) (1) (J) (ii). 2. Excess Profits Tax -- Exclusion of Income of Taxable Year -- Section 711 (a) (1) (E). -- Salvage recovered by a surety after paying claims of insured is not recovery of bad debts within the meaning…
1Opinion of the Court
Great American Indemnity Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Great American Indem. Co. v. Commissioner
Docket No. 31086
United States Tax Court
19 T.C. 229; 1952 U.S. Tax Ct. LEXIS 50;
November 12, 1952, Promulgated
Decision will be entered for the respondent.
1. Excess Profits Tax -- Abnormal Deduction -- Surety Loss -- Class -- Section 711 (b) (1) (J) (i) and (ii). -- A deduction taken in 1939 for an anticipated loss on a surety bond was not a separate class and abnormal within section 711 (b) (1) (J) (i) and the surety code number under which it was classified did…
2Cases cited3 opinions
- George J. Meyer Malt & Grain Corp. v. CommissionerUnited States Tax Court · 1948
- Great American Indem. Co. v. CommissionerUnited States Tax Court · 1952
- Beneficial Industrial Loan Corp. v. CommissionerUnited States Tax Court · 1946