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
OPINION.
Opper, Judge:
Respondent has determined deficiencies against petitioner and an overassessment as follows:
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The questions presented are:
1. How should petitioner compute in United States dollars the income of a Canadian branch which maintains accounts and records income in Canadian dollars ?
2. May erroneous treatment of an item in determining taxable income of a base period year be corrected in the computation of the excess profits credit based on income?
3. Does the Tax Court have jurisdiction over standard excess profits tax issues for the year ended September 30, 1941, for…
2Cases cited5 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
- Frederick Vietor & Achelis v. Salt's Textile Mfg. Co.District Court, D. Connecticut · 1928
3Cited by14 opinions
- Columbian Rope Co. v. CommissionerUnited States Tax Court · 1964
- Dubuque Packing Company v. United StatesDistrict Court, N.D. Iowa · 1954
- Commissioner of Internal Revenue v. Seminole Manufacturing CompanyCourt of Appeals for the Fifth Circuit · 1956
- Travelers Insurance v. United StatesUnited States Court of Federal Claims · 1996
- Bulova Watch Co. v. United StatesUnited States Court of Claims · 1958
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