Legal Opinion
Commissioner of Internal Revenue v. Birch Ranch & Oil Co
Court of Appeals for the Ninth Circuit
Decided November 19, 1951No. 12639PublishedCited by 10 opinions
1Opinion of the Court
POPE, Circuit Judge.
The Tax Court held that the respondent taxpayer-corporation was entitled to deduct payments made by it to a California reclamation district, upon assessment calls for sums required for district bond interest charges, and thus compute a net operating loss for fiscal year 1944. If such loss existed, it is conceded that it may constitute a carry-back deduction for fiscal 1942, the year for which a deficiency had been determined by the Commissioner.
Upon this, petition for review, the Commissioner contends that under the circumstances presented here, the payment was not…
2Cases cited5 opinions
- Clark v. NashSupreme Court of the United States · 1905
- Denman v. SlaytonSupreme Court of the United States · 1931
- Prudence Securities Corporation v. Com'r of Int. Rev.Court of Appeals for the Second Circuit · 1943
- Birch Ranch & Oil Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1946
- Rindge Land & Navigation Co. v. CommissionerUnited States Board of Tax Appeals · 1925
3Cited by10 opinions
- Foster v. Comm'rUnited States Tax Court · 1983
- Saigh v. CommissionerUnited States Tax Court · 1961
- Foster v. CommissionerCourt of Appeals for the Ninth Circuit · 1985
- Foster v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
- Commissioner of Internal Revenue v. Birch Ranch & Oil CoCourt of Appeals for the Ninth Circuit · 1951
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