Kentucky Farm & Cattle Co. v. Commissioner
United States Tax Court
1. Held, that in determining the excess profits credit for the years 1950 and 1951 and the unused excess profits credit to be carried back from 1952 to 1951 of an affiliated group with one section 445 subsidiary, where there were unrealized profits in 1949 and 1950 resulting from intercompany transactions consisting of sales of tobacco by the parent to its section 445 "new" corporation subsidiary, petitioner is entitled to have included in the parent's assets for 1949 and…
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1. Held, that in determining the excess profits credit for the years 1950 and 1951 and the unused excess profits credit to be carried back from 1952 to 1951 of an affiliated group with one section 445 subsidiary, where there were unrealized profits in 1949 and 1950 resulting from intercompany transactions consisting of sales of tobacco by the parent to its section 445 "new" corporation subsidiary, petitioner is entitled to have included in the parent's assets for 1949 and 1950 the amount of cash paid to the parent by the subsidiary, but the respective equivalent amounts reflected as net…
1Opinion of the Court
OPINION.
Fisher, Judge:
Respondent determined deficiencies against petitioner in consolidated income tax for the following years and in the following amounts:
1950 _$1, 747.17
1951_ 29,867.75
The year 1952 is also involved by way of carryback of unused excess profits credit. The questions presented are:
1. In determining the excess profits credit for the years 1950 and 1951, and the unused excess profits credit to be carried back from 1952 to 1951 of an affiliated group with one section 4451 subsidiary, where there were unrealized profits in 1949 and 1950 resulting from intercompany transactions…
2Cases cited9 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Morton v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1940
- Bangor & A. R. Co. v. CommissionerUnited States Tax Court · 1951
- Bangor & Aroostook R. Co. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1951
- Leicht v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1943
4 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Meyer v. CommissionerUnited States Tax Court · 1966
- Henry C. Beck Co. v. CommissionerUnited States Tax Court · 1969
- Henry C. Beck Co. v. CommissionerUnited States Tax Court · 1969
- Kentucky Farm & Cattle Co. v. CommissionerUnited States Tax Court · 1958
- Meyer v. CommissionerUnited States Tax Court · 1966