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H. S. McCLELLAND, INC. v. COMMISSIONER

Docket No. 15558.

14 T.C. 45 (1950)

H. S. McCLELLAND, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated January 19, 1950.

Attorney(s) appearing for the Case

F. T. Ritter, C. P. A., for the petitioner.

H. A. Melville, Esq., and John D. Kiley, Esq., for the respondent.

The Commissioner determined a deficiency of $1,760.21 in petitioner's excess profits tax for the fiscal year ended April 30, 1941, in part by restoring to excess profits net income $11,021.87 which petitioner deducted on its return as "abnormal income attributable to other years." Petitioner claimed that one-fourth of this amount represented "taxable income, under section 734 of the Internal Revenue Code, for each of the taxable years...

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