George J. Meyer Malt & Grain Corp. v. Commissioner
United States Tax Court
1. The taxpayer, in computing excess profits tax for 1943 and 1944, sought disallowance of abnormal bad debt deductions for 1938 and 1940. The Commissioner refused to permit such a disallowance. In its petition the taxpayer asserted error only as to the refusal by the Commissioner to permit disallowance in 1940. The petitioner computed its excess profits credit under the growth formula.
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1. The taxpayer, in computing excess profits tax for 1943 and 1944, sought disallowance of abnormal bad debt deductions for 1938 and 1940. The Commissioner refused to permit such a disallowance. In its petition the taxpayer asserted error only as to the refusal by the Commissioner to permit disallowance in 1940. The petitioner computed its excess profits credit under the growth formula. The Commissioner, by answer, asked that, if the bad debt deduction be disallowed for 1940, the 1938 deduction be also disallowed. By petitioner's evidence and by stipulation it was established that both in…
1Opinion of the Court
OPINION.
HaRlan, Judge:
Petitioner, in the excess profits tax returns involved herein, claimed that certain deductions taken in the base period were abnormal and computed its excess profits credit accordingly. The respondent rejected all of these claimed abnormal items. This controversy between the parties turns upon section 711 (b) (1) (J) and (K) of the Internal Revenue Code, the relevant portions of which are set forth in the margin.1
The first deduction for our present consideration, which petitioner took in 1940 because of an alleged bad debt and which it now seeks to have disallowed, is…
2Cases cited6 opinions
- Green Bay Lumber Co. v. CommissionerUnited States Tax Court · 1944
- Arrow-Hart & Hegeman Electric Co. v. CommissionerUnited States Tax Court · 1946
- City Auto Stamping Co. v. CommissionerUnited States Tax Court · 1946
- Colson Corp. v. CommissionerUnited States Tax Court · 1945
- Rockford Varnish Co. v. CommissionerUnited States Tax Court · 1947
1 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Dunlap & Associates, Inc. v. CommissionerUnited States Tax Court · 1967
- Industrial Loan Soc. v. CommissionerUnited States Tax Court · 1950
- Myers v. CommissionerUnited States Tax Court · 1949
- Colorado Milling & Elevator Co. v. CommissionerUnited States Tax Court · 1952
- Colorado Milling & Elevator Co. v. CommissionerUnited States Tax Court · 1952
5 more not listed; retrieve them via the Exa API.