Legal Opinion

William A. Webster Co. v. Commissioner

United States Board of Tax Appeals

Decided May 5, 1938No. Docket No. 88700Published

Petitioner filed its capital stock tax returns on July 29, 1933, disclosing an original declared value for its entire capital stock of $395,157. Thereafter, on September 8, 1933, within the time for filing capital stock tax returns for that year, petitioner filed an "amended return" which disclosed a declared value for its capital stock of $800,000. Respondent declined to recognize the "amended return" and computed deficiencies in petitioner's income and excess profits taxes…

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Petitioner filed its capital stock tax returns on July 29, 1933, disclosing an original declared value for its entire capital stock of $395,157. Thereafter, on September 8, 1933, within the time for filing capital stock tax returns for that year, petitioner filed an "amended return" which disclosed a declared value for its capital stock of $800,000. Respondent declined to recognize the "amended return" and computed deficiencies in petitioner's income and excess profits taxes on the basis of the stock value declared by petitioner in its first return, pursuant to the provisions of sections…

1Opinion of the Court

WILLIAM A. WEBSTER COMPANY, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

William A. Webster Co. v. Commissioner

Docket No. 88700.

United States Board of Tax Appeals

37 B.T.A. 800; 1938 BTA LEXIS 982;

May 5, 1938, Promulgated

Petitioner filed its capital stock tax returns on July 29, 1933, disclosing an original declared value for its entire capital stock of $395,157. Thereafter, on September 8, 1933, within the time for filing capital stock tax returns for that year, petitioner filed an "amended return" which disclosed a declared value for its capital stock of $800,000.…

2Cases cited4 opinions

  1. Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
  2. City of Lincoln v. RickettsSupreme Court of the United States · 1936
  3. William A. Webster Co. v. CommissionerUnited States Board of Tax Appeals · 1938
  4. Automobile Loans, Inc. v. CommissionerUnited States Board of Tax Appeals · 1937

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