Girard Trust Corn Exchange Bank v. Commissioner
United States Tax Court
1. The unused excess profits credit of the petitioner for a taxable year beginning December 1, 1943, is to be computed on the prorated basis under both the 1943 and 1944 laws, as required by section 710 (a) (6), Internal Revenue Code of 1939, added by section 203 (a), Revenue Act of 1943, notwithstanding the provision that the 1943 amendments were applicable only to years beginning after December 31, 1943. 2. Real estate acquired by a bank in foreclosures and by deeds in…
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1. The unused excess profits credit of the petitioner for a taxable year beginning December 1, 1943, is to be computed on the prorated basis under both the 1943 and 1944 laws, as required by section 710 (a) (6), Internal Revenue Code of 1939, added by section 203 (a), Revenue Act of 1943, notwithstanding the provision that the 1943 amendments were applicable only to years beginning after December 31, 1943. 2. Real estate acquired by a bank in foreclosures and by deeds in lieu thereof was held primarily for sale to customers in the ordinary course of the petitioner's business and sales thereof…
1Opinion of the Court
Girard Trust Corn Exchange Bank, Petitioner, v. Commissioner of Internal Revenue, Respondent
Girard Trust Corn Exchange Bank v. Commissioner
Docket No. 36015
United States Tax Court
22 T.C. 1343; 1954 U.S. Tax Ct. LEXIS 86;
September 30, 1954, Filed September 30, 1954, Filed
Decision will be entered under Rule 60.
1. The unused excess profits credit of the petitioner for a taxable year beginning December 1, 1943, is to be computed on the prorated basis under both the 1943 and 1944 laws, as required by section 710 (a) (6), Internal Revenue Code of 1939, added by section 203 (a), Revenue Act of 1943,…
2Cases cited21 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Thrift v. CommissionerUnited States Tax Court · 1950
- MAULDIN v. COMMISSIONER OF INTERNAL REVENUE (Two Cases)Court of Appeals for the Tenth Circuit · 1952
- Rollingwood Corp. v. Commissioner of Internal Revenue. Bohannon v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1951
- Mauldin v. CommissionerUnited States Tax Court · 1951
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