PACIFIC GAS & ELECTRIC CO. v. COMMISSIONER

Docket No. 7966.

7 T.C. 1142 (1946)

PACIFIC GAS AND ELECTRIC COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 13, 1946.


Attorney(s) appearing for the Case

Arthur H. Kent, Esq., Valentine Brookes, Esq., and Robert H. Gerdes, Esq., for the petitioner.

T. M. Mather, Esq., for the respondent.


The Commissioner determined deficiencies of $1,619,074.50 and $2,114,622.33 in the petitioner's excess profits tax for 1941 and 1942. The petitioner assigns as error the failure of the Commissioner to disallow the following abnormal deductions for 1939 in computing the petitioner's excess profits credit based upon income under section 713:

(a) $668,067.70 representing the portion of refunds made in 1939 on excessive gas rates collected in 1936.

(b) $206,616...

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