American Pad & Textile Co. v. Commissioner
United States Tax Court
1. Petitioner's income from operations conducted through a Canadian branch, held properly accounted for by converting Canadian income into United States dollars at current rate of exchange so as to entitle petitioner to excess profits credit computed by use of same method for other base period years when different and unauthorized methods had been employed.
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1. Petitioner's income from operations conducted through a Canadian branch, held properly accounted for by converting Canadian income into United States dollars at current rate of exchange so as to entitle petitioner to excess profits credit computed by use of same method for other base period years when different and unauthorized methods had been employed. Leonard Refineries, Inc., 11 T. C. 1000, followed. 2. Excess profits tax issues for period for which no deficiency had been determined, held subject to dismissal for lack of jurisdiction on authority of Mutual Lumber Co., 16 T. C. 370.
1Opinion of the Court
The American Pad & Textile Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
American Pad & Textile Co. v. Commissioner
Docket No. 20295
United States Tax Court
16 T.C. 1304; 1951 U.S. Tax Ct. LEXIS 166;
June 11, 1951, Promulgated
Decision will be entered under Rule 50.
1. Petitioner's income from operations conducted through a Canadian branch, held properly accounted for by converting Canadian income into United States dollars at current rate of exchange so as to entitle petitioner to excess profits credit computed by use of same method for other base period years when different…
2Cases cited6 opinions
- Mutual Lumber Co. v. CommissionerUnited States Tax Court · 1951
- Leonard Refineries, Inc. v. CommissionerUnited States Tax Court · 1948
- B. F. Goodrich Co. v. CommissionerUnited States Tax Court · 1943
- Foundation Co. v. CommissionerUnited States Tax Court · 1950
- American Pad & Textile Co. v. CommissionerUnited States Tax Court · 1951
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