Legal Opinion
Commissioner of Internal Revenue v. Hecht Co.
Court of Appeals for the Fourth Circuit
Decided July 19, 1947No. 5595PublishedCited by 4 opinions
1Opinion of the Court
SOPER, Circuit Judge.
The Commissioner of Internal Revenue appeals from a decision of the Tax Court whereby Section 30.736(a)-3 of Treasury Regulations 109 was declared invalid insofar as it prohibits the allowance of deductions (including deductions for bad debts) in the computation of excess profits net income for any excess profits taxable year on account of installment sales made before January 1, 1940, by a taxpayer who has been computing its income from installment sales on the installment basis and has elected to change its method of accounting and compute its income on the accrual…
2Cases cited5 opinions
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Mackin Corp. v. CommissionerUnited States Tax Court · 1946
- KIMBRELL'S HOME FURNISH. v. Commissioner of Int. Rev.Court of Appeals for the Fourth Circuit · 1947
- Hecht Co. v. CommissionerUnited States Tax Court · 1946
3Cited by4 opinions
- Hadley Furniture Co. v. United StatesDistrict Court, D. Massachusetts · 1949
- Commissioner v. Mackin Corp.Court of Appeals for the First Circuit · 1947
- Leo Kahn Furniture Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1952
- Blatchford v. CommissionerUnited States Tax Court · 1963