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PHILADELPHIA FIRE & MARINE INS. CO. v. UNITED STATES

No. M-390.

3 F.Supp. 655 (1933)

PHILADELPHIA FIRE & MARINE INS. CO. v. UNITED STATES.

Court of Claims.

May 29, 1933.

Attorney(s) appearing for the Case

James Craig Peacock, of Washington, D. C. (John W. Townsend, of Washington, D. C., on the brief), for plaintiff.

Lisle A. Smith and E. H. Horton, both of Washington, D. C., and Charles B. Rugg, Asst. Atty. Gen., for the United States.

Before GREEN, LITTLETON, WILLIAMS, and WHALEY, Judges.

LITTLETON, Judge.

The computation of the amount of the net loss for 1926 which was allowed by the defendant as a deduction from plaintiff's income for 1927 was in accordance with the provisions of section 206 of the Revenue Act of 1926 (26 USCA § 937), and this is not questioned, but plaintiff contends that the entire loss for 1926 of $92,447.31, representing the excess of allowable deductions over its taxable gross income, was deductible from net income for...

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