Legal Opinion

Foundation Co. v. Commissioner

United States Tax Court

Decided June 30, 1950No. Docket No. 10448Published

Issue 1. Upon the facts, held, the respondent correctly disallowed deduction in 1940 of an alleged expense. Issue 2. Petitioner entered into a contract with a Peruvian corporation under which the consideration was to be paid in soles. The corporation defaulted in payments, which gave rise to a debt. The value of soles declined after the debt accrued. Petitioner reported income on the accrual basis.

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Issue 1. Upon the facts, held, the respondent correctly disallowed deduction in 1940 of an alleged expense. Issue 2. Petitioner entered into a contract with a Peruvian corporation under which the consideration was to be paid in soles. The corporation defaulted in payments, which gave rise to a debt. The value of soles declined after the debt accrued. Petitioner reported income on the accrual basis. Held, upon the facts, that petitioner sustained losses upon the conversion of the depreciated soles which it received in payment of the debt. B. F. Goodrich, 1 T. C. 1098, distinguished; held,…

1Opinion of the Court

The Foundation Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Foundation Co. v. Commissioner

Docket No. 10448

United States Tax Court

14 T.C. 1333; 1950 U.S. Tax Ct. LEXIS 131;

June 30, 1950, Promulgated

Decision will be entered under Rule 50.

Issue 1. Upon the facts, held, the respondent correctly disallowed deduction in 1940 of an alleged expense.

Issue 2. Petitioner entered into a contract with a Peruvian corporation under which the consideration was to be paid in soles. The corporation defaulted in payments, which gave rise to a debt. The value of soles declined after the…

2Cases cited10 opinions

  1. Lucas v. American Code Co.Supreme Court of the United States · 1930
  2. Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
  3. Boehm v. CommissionerSupreme Court of the United States · 1945
  4. Lewellyn v. Electric Reduction Co.Supreme Court of the United States · 1927
  5. Heiner v. MellonSupreme Court of the United States · 1938

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