Logan v. Commissioner
United States Tax Court
In their amended petition for redetermination of an income tax deficiency, Ps claimed that R failed to allow credit for overpaid windfall profit tax. R moved to dismiss for lack of jurisdiction and to strike that portion of the petition that pertains to the credit for overpaid windfall profit tax under sec. 6429, I.R.C. 1954 as amended.
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In their amended petition for redetermination of an income tax deficiency, Ps claimed that R failed to allow credit for overpaid windfall profit tax. R moved to dismiss for lack of jurisdiction and to strike that portion of the petition that pertains to the credit for overpaid windfall profit tax under sec. 6429, I.R.C. 1954 as amended. Held: The Tax Court has no jurisdiction to redetermine the credit for overpaid windfall profit tax in an income tax proceeding since no notice of deficiency relating to windfall profit tax has been issued. However, in redetermining the deficiency in income…
1Opinion of the Court
Russell E. Logan and Ellen Logan, Petitioners v. Commissioner of Internal Revenue, Respondent
Logan v. Commissioner
Docket No. 14386-85
United States Tax Court
86 T.C. 1222; 1986 U.S. Tax Ct. LEXIS 95; 86 T.C. No. 71; 91 Oil & Gas Rep. 649;
June 18, 1986, Filed
In their amended petition for redetermination of an income tax deficiency, Ps claimed that R failed to allow credit for overpaid windfall profit tax. R moved to dismiss for lack of jurisdiction and to strike that portion of the petition that pertains to the credit for overpaid windfall profit tax under sec. 6429, I.R.C. 1954 as amended.…
2Cases cited22 opinions
- Breman v. CommissionerUnited States Tax Court · 1976
- Hannan v. CommissionerUnited States Tax Court · 1969
- Medeiros v. CommissionerUnited States Tax Court · 1981
- Midland Mortg. Co. v. CommissionerUnited States Tax Court · 1980
- Commissioner of Internal Revenue v. LindeCourt of Appeals for the Ninth Circuit · 1954
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