Snyder Air Products, Inc. v. Commissioner
United States Tax Court
Held, on an accrual basis of accounting petitioner's gain resulting from an award for condemnation of its property is taxable in its fiscal year ended May 31, 1970, the year in which all appeals were exhausted and the award became final. Held, further, petitioner failed to carry its burden of proving error in respondent's disallowance of various miscellaneous deductions.
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Held, on an accrual basis of accounting petitioner's gain resulting from an award for condemnation of its property is taxable in its fiscal year ended May 31, 1970, the year in which all appeals were exhausted and the award became final. Held, further, petitioner failed to carry its burden of proving error in respondent's disallowance of various miscellaneous deductions. Held, further: Additions to tax under sec. 6651(a) upheld for both 1968 and 1970. Addition to tax under sec. 6653(a) for 1968 not upheld.
1Opinion of the Court
Drennen, Judge:
In these consolidated cases respondent determined deficiencies and additions to tax as follows:
Addition to tax, I.R.C. 195k1 Docket
Year Deficiency Sec. 6651(a) Sec. 6653(a) No.
FYE 5/31/68 $37,748.78 $9,437.19 $1,887.44 8211-75
FYE 5/31/70 6,175.87 1,543.97 3486-75
Several of the issues relative to the deficiencies have been settled by stipulation of the parties. The issues remaining for our resolution are:(1) Whether a condemnation award from the State of New York accrued during petitioner’s fiscal year ending May 31,1968. If not, whether it accrued during petitioner’s fiscal…
2Cases cited6 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Williams v. CommissionerUnited States Tax Court · 1951
- Koppers Co. v. CommissionerUnited States Tax Court · 1944
- Patrick McGuirl, Inc. v. Commissioner of Internal Rev.Court of Appeals for the Second Circuit · 1935
- General Baking Co. v. CommissionerUnited States Tax Court · 1967
1 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Beauty Acquisition Corp. v. CommissionerUnited States Tax Court · 1995
- APPEL v. COMMISSIONERUnited States Tax Court · 2004
- De Vaughn v. CommissionerUnited States Tax Court · 1983
- Hale v. CommissionerUnited States Tax Court · 1982
- Snyder Air Products, Inc. v. CommissionerUnited States Tax Court · 1979
1 more not listed; retrieve them via the Exa API.