W.H. Loomis Talc Corp. v. Comm'r of Internal Revenue

2 Citing cases

  1. City Auto Stamping Co. v. Comm'r of Internal Revenue

    7 T.C. 354 (U.S.T.C. 1946)   Cited 8 times

    It is a manufacturing corporation, plainly not one where claims, litigation, and judgments might be considered usual incidents to its business. See W. H. Loomis Talc Corporation, 3 T.C. 1067; Consolidated Motor Lines, Inc., 6 T.C. 1066. We consider this so self-evident as to obviate further comment, and that the only question is whether the regulation, in effect denying abnormality of deduction unless there is none of that class in the period used to secure an average, is valid as applied in this case.

  2. Consol. Motor Lines, Inc. v. Comm'r of Internal Revenue

    6 T.C. 1066 (U.S.T.C. 1946)   Cited 6 times

    We view all these matters as normally incident to the business of the petitioner and not involving any concept of the abnormality which the intent of the statute requires for disallowance. The amounts expended on them were to the petitioner all ‘recurring expenses‘ and ‘of the nature of ordinary and necessary expenses,‘ as we said in W. H. Loomis Talc Corporation, 3 T.C. 1067, with reference to payments to compensate workmen for injuries. This is indicated not only by the character of the business and operations as shown in the evidence, but by the large amounts involved in the ‘losses‘ claimed.