Colip v. Commissioner
United States Board of Tax Appeals
1. The provisions of Title XII Revenue Act of 1924 allowing a credit or refund of 25 per cent of the tax shown by 1923 returns did not reduce the rates of 1923 within the meaning of section 207(b). 2. The 25 per cent reduction provided by Title XII Revenue Act of 1924 is applicable literally to the tax payable in 1924 shown on returns for 1923, and does not reduce the 1924 tax payable in 1925 of an individual partner whose 1924 taxable income is made up in part of a share of…
Read the full summary
1. The provisions of Title XII Revenue Act of 1924 allowing a credit or refund of 25 per cent of the tax shown by 1923 returns did not reduce the rates of 1923 within the meaning of section 207(b). 2. The 25 per cent reduction provided by Title XII Revenue Act of 1924 is applicable literally to the tax payable in 1924 shown on returns for 1923, and does not reduce the 1924 tax payable in 1925 of an individual partner whose 1924 taxable income is made up in part of a share of partnership income for a fiscal year beginning in 1923. 3. In taxing a partner's income for a calendar year, such…
1Opinion of the Court
OPINION.
Steenhagen:
This case is one of several, all presented together upon agreed facts. [See pp. 127-133, infra.~\ The dispute is founded in the Commissioner’s application of the 25 per cent reduction prescribed by Title XII of the Revenue Act of 1924. In each case the individual petitioner in 1925 made his return for the calendar year 1924. In this return, pursuant to section 218 and section 207 (b), *124Revenue Act of 1924, lie included as 1924 income his distributive share of partnership net income for its fiscal year ending in 1924, part of which in each case was in 1923. Upon the basis of…
2Cited by13 opinions
- Archbald v. CommissionerUnited States Board of Tax Appeals · 1933
- Colip v. CommissionerUnited States Board of Tax Appeals · 1926
- Johnston v. CommissionerUnited States Board of Tax Appeals · 1936
- McFetridge v. CommissionerUnited States Board of Tax Appeals · 1927
- McFetridge v. CommissionerUnited States Board of Tax Appeals · 1927
8 more not listed; retrieve them via the Exa API.