Laredo Bridge Co. v. Commissioner
United States Tax Court
Taxpayer corporation sustained a capital loss of $ 68,575.53 in 1937 as the result of the condemnation by the Mexican Government of the Mexican end of the international bridge at Laredo, Texas, built and owned by petitioner. The loss was abnormal for petitioner, and was the cause rather than the consequence, of a change in the size of its business.
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Taxpayer corporation sustained a capital loss of $ 68,575.53 in 1937 as the result of the condemnation by the Mexican Government of the Mexican end of the international bridge at Laredo, Texas, built and owned by petitioner. The loss was abnormal for petitioner, and was the cause rather than the consequence, of a change in the size of its business. Held, the loss should be disregarded by virtue of section 711 (b) (1) (J) in computing petitioner's excess profits net income for 1937, one of the base years involved in the computation of its 1941 excess profits tax liability.
1Opinion of the Court
OPINION.
Kern, Judge-.
It is the contention of the petitioner that the loss which it sustained in 1937 by reason of the condemnation of the Mexican end of its bridge by the Mexican Government must be disregarded in determining its excess profits net income for 1937, one of the base years involved in the computation of petitioner’s excess profits tax liability for 1941. Petitioner urges that this adjustment is authorized either as an abnormal deduction within the meaning of section 711 (b) (1) (J) of the Internal Eevenue Code, or as a long term capital loss, covered by section 711 (b) (2) of the…
2Cases cited4 opinions
- Monroe v. Hartford Street Railway Co.Supreme Court of Connecticut · 1903
- In Re BensonSupreme Court of Oklahoma · 1936
- Kelsey v. RebuzziniSupreme Court of Connecticut · 1913
- Hill v. DaySuperior Court of Delaware · 1938
3Cited by9 opinions
- Mine & Smelter Supply Co. v. CommissionerUnited States Tax Court · 1948
- Rockford Screw Products Co. v. CommissionerUnited States Tax Court · 1954
- A. B. Carter, Inc. v. CommissionerUnited States Tax Court · 1950
- Corn Prods. Ref. Co. v. CommissionerUnited States Tax Court · 1952
- Godson v. CommissionerUnited States Tax Court · 1946
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