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QUINCY MINING COMPANY v. UNITED STATES

No. 467-53.

156 F.Supp. 913 (1957)

QUINCY MINING COMPANY v. UNITED STATES.

United States Court of Claims.

December 4, 1957.

Attorney(s) appearing for the Case

Montgomery B. Angell, New York City, Wallace S. Jones, and Davis, Polk, Wardwell, Sunderland & Kiendl, New York City, on the brief, for plaintiff.

John A. Rees, Washington, D. C., with whom was Charles K. Rice, Asst. Atty. Gen., James P. Garland, Washington, D. C., on the brief, for defendant.

MADDEN, Judge.

The plaintiff sues to recover income taxes collected from it for the year 1947. Its liability for the taxes depends upon its right to deduct from its gross sales for that year and the year 1948 certain expenses incurred by its predecessor during the years 1919, 1920, and 1921. Those expenses bore a relation, which will appear hereinafter, to its gross sales in 1947. The year 1948 is involved only because of a claimed carryback of losses from that year...

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