Brief Fact Summary. Respondent was in the natural gas business in Oklahoma. After a change in the minimum price order on natural gas, Respondent had to refund a large amount of money to customers previously claimed as gross income.
Synopsis of Rule of Law. If a taxpayer was not entitled to keep money, he is entitled to a deduction in the year it is refunded.
But where the benefit claimed by the taxpayer is fairly within the statutory language and the construction sought is in harmony with the statute as an organic whole, the benefits will not be withheld from the taxpayer though they represent an unexpected windfall.View Full Point of Law