Legal Opinion
Smith Electric Co. v. United States
United States Court of Claims
Decided June 16, 1972No. 474-69PublishedCited by 4 opinions
1Opinion of the CourtKuNzig, Judge
This case is before us on a stipulation of facts. Plaintiff is suing for the recovery of Federal Income taxes for the years 1957 and 1958 in the respective amounts of $5,738.01 and $10,960.19, plus interest.
The sole issue in this case is whether the special seven-year statute of limitations,1 with respect to filing claims for refund on account of the deductibility of a worthless debt, is applicable to taxpayers on the reserve method as well as to those on the direct charge-off method.
Plaintiff is an accrual basis taxpayer who utilizes the reserve method of treating bad debts. In 1960,…
2Cases cited10 opinions
- Lynch v. Alworth-Stephens Co.Supreme Court of the United States · 1925
- Roanoke Vending Exchange, Inc. v. CommissionerUnited States Tax Court · 1963
- Platt Trailer Co. v. CommissionerUnited States Tax Court · 1955
- Helvering v. Edison Securities CorporationCourt of Appeals for the Fourth Circuit · 1935
- New York Water Service Corp. v. CommissionerUnited States Tax Court · 1949
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3Cited by4 opinions
- AmBase Corp. v. United StatesCourt of Appeals for the Second Circuit · 2013
- Indiana National Corporation and Its Subsidiaries: Indiana National Bank v. United StatesCourt of Appeals for the Seventh Circuit · 1992
- Indiana National Corp. v. United StatesDistrict Court, S.D. Indiana · 1991
- Winter & Hirsch, Inc. v. United StatesUnited States Court of Claims · 1978