A. Finkenberg's Sons, Inc. v. Commissioner
United States Tax Court
1. Because of an ambiguity in the deficiency notice statement of the nature of the disallowance, petitioner contends that a questioned deduction is not properly before the Court.
Read the full summary
1. Because of an ambiguity in the deficiency notice statement of the nature of the disallowance, petitioner contends that a questioned deduction is not properly before the Court. Held, the issue was raised because the only ambiguity was in the explanation of the deduction, and the taxpayer had reasonable notice, examined the issue and was not prejudiced. 2. Petitioner, an installment dealer, deducted in 1944 expenses of $ 22,780.30, which were disallowed because they were incurred in prior years in connection with a promotional campaign. Held, the petitioner was not entitled to a deduction in…
1Opinion of the Court
A. Finkenberg's Sons, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
A. Finkenberg's Sons, Inc. v. Commissioner
Docket No. 27230
United States Tax Court
17 T.C. 973; 1951 U.S. Tax Ct. LEXIS 17;
December 10, 1951, Promulgated
Decision will be entered under Rule 50.
1. Because of an ambiguity in the deficiency notice statement of the nature of the disallowance, petitioner contends that a questioned deduction is not properly before the Court. Held, the issue was raised because the only ambiguity was in the explanation of the deduction, and the taxpayer had reasonable notice, examined…
2Cases cited9 opinions
- Commissioner of Internal Revenue v. StewartCourt of Appeals for the Sixth Circuit · 1951
- Standard Oil Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1942
- A. Finkenberg's Sons, Inc. v. CommissionerUnited States Tax Court · 1951
- X-Pando Corp. v. CommissionerUnited States Tax Court · 1946
- Hay v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1944
4 more not listed; retrieve them via the Exa API.