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PORTLAND COPPER & TANK WORKS, INC. v. COMMISSIONER OF INTERNAL REVENUE

No. 6510.

351 F.2d 460 (1965)

PORTLAND COPPER & TANK WORKS, INC., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals First Circuit.

Decided October 14, 1965.

Attorney(s) appearing for the Case

John M. Doukas, Washington, D. C., with whom Maloney, Williams, Baer & Doukas, Boston, Mass., was on brief, for petitioner.

Loring W. Post, Atty., Dept. of Justice, with whom John B. Jones, Jr., Acting Asst. Atty. Gen., and Lee A. Jackson and Harry Baum, Attys., Dept. of Justice, were on brief, for respondent.

Before ALDRICH, Chief Judge, J. WARREN MADDEN, Senior Judge, Court of Claims and JULIAN, District Judge.

PER CURIAM.

Essentially this case involves the single question whether an accrual taxpayer which has received payments under subcontracts subject to renegotiation under goverment procurement statutes may set up as a reserve, and accordingly deduct from gross income, amounts which by assertedly and, we will assume, concededly, proper accounting methods it appeared during the taxable year would later have to be repaid. The Tax Court rejected taxpayer's contention. ...

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