Joseph Weidenhoff, Inc. v. Commissioner
United States Tax Court
1. In computing the amount of net operating loss for the year 1947 absorbed by carryback to the year 1945 under section 122(b) (1) and (2), I.R.C. 1939, the net income for the year 1945 against which the carryback is applied is to be reduced under section 122(d)(6) by the excess profits tax accrued for the year 1945, which is the excess profits tax computed to be due less the deferral in payment provided under section 710(a)(5) and less the 10 per cent credit provided under…
Read the full summary
1. In computing the amount of net operating loss for the year 1947 absorbed by carryback to the year 1945 under section 122(b) (1) and (2), I.R.C. 1939, the net income for the year 1945 against which the carryback is applied is to be reduced under section 122(d)(6) by the excess profits tax accrued for the year 1945, which is the excess profits tax computed to be due less the deferral in payment provided under section 710(a)(5) and less the 10 per cent credit provided under section 784. 2. That portion of the consolidated net operating losses of the affiliated group for the years 1948 and…
1Opinion of the Court
OPINION.
ÜREnnen, Judge:
This consolidated proceeding involves deficiencies in income and excess profits taxes determined against petitioners as follows:
Docket No. Petitioner Year Deficiency
60793 Joseph Weidenhoff, Incorporated_ 1946 $16,788.46
60794 Johnson Fare Box Company, Alleged Transferee-1946 11,890.58
60795 Bowser International, Inc._ 1947 344.81
60796 Bowser, Inc. and its Subsidiaries, et aL.
1951 1711,316.80
1952 92,492.36
These cases were submitted on a stipulation of all facts under Hule 30. The facts are found as stipulated and the stipulation, together with the exhibits attached…
2Cases cited21 opinions
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- United States v. Olympic Radio & Television, Inc.Supreme Court of the United States · 1955
- Lewyt Corp. v. CommissionerSupreme Court of the United States · 1955
- Burnet v. Aluminum Goods Manufacturing Co.Supreme Court of the United States · 1933
16 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- American Standard, Inc. v. United StatesUnited States Court of Claims · 1979
- Consolidated Freightways, Inc. & Affiliates v. CommissionerUnited States Tax Court · 1980
- BBS Associates, Inc. v. CommissionerUnited States Tax Court · 1980
- Clarksdale Rubber Co. v. CommissionerUnited States Tax Court · 1965
- Morris v. CommissionerUnited States Tax Court · 1978
25 more not listed; retrieve them via the Exa API.