# New Orleans Cold Storage & Warehouse Co. v. Commissioner > United States Board of Tax Appeals · June 22, 1939 · 40 B.T.A. 121 URL: https://www.frixlaw.com/law-library/cases/4497628 ## Case - **Full name:** NEW ORLEANS COLD STORAGE AND WAREHOUSE COMPANY, LTD., v. COMMISSIONER OF INTERNAL REVENUE - **Court:** United States Board of Tax Appeals - **Decided:** June 22, 1939 - **Citations:** 40 B.T.A. 121; 1939 BTA LEXIS 892 - **Precedential status:** Published - **Opinion:** Dissent by Black - **Judges:** Black, Smith, Leech - **Cited by:** 4 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4497628 ## Opinion text Black, dissenting: I respectfully dissent from the majority opinion because, as I view the facts, no taxes accrued against petitioner during the period from March 1 to December 31,1936. That is the period that we have before us. Petitioner kept its books on the accrual basis. Therefore, since no taxes accrued against petitioner during the period' in question, it would have no right to take a deduction for taxes accrued during such period. I think the Commissioner should be sustained. Leech agrees with this dissent. --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4497628. Public record. Not legal advice.