Brighton Mills, Inc. v. Commissioner
United States Tax Court
Under the authority of Security Flour Mills Co. v. Commissioner, 321 U.S. 281, it is held that petitioner can not deduct in 1935 amounts refunded to customers after January 6, 1936, when the A. A. A. processing taxes were held invalid. The principle of Sanford Cotton Mills, 42 B. T. A. 190, held, inapplicable in view of Supreme Court's holding in Security Flour Mills Co. v. Commissioner, supra, and Sanford Cotton Mills will not be followed hereafter.
1Opinion of the Court
OPINION.
HaRkon, Judge:
The facts have been stipulated. The stipulation of facts is incorporated herein and is adopted as our findings of fact.
The facts necessary to understand the question can be stated briefly as follows: Petitioner, a Georgia corporation, was a processor of cotton during 1935. It kept its books and reported its income on the accrual basis. Petitioner paid processing taxes for cotton processed under the Agricultural Adjustment Act of 1933, during one month only in 1935, the month of January. Thereafter, it did not pay any processing taxes due, but only accrued such taxes on…
2Cases cited3 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
3Cited by10 opinions
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- Lehigh v. R. Co. v. CommissionerUnited States Tax Court · 1949
- Simon v. CommissionerUnited States Tax Court · 1948
- Cuba Railroad Co. v. CommissionerUnited States Tax Court · 1947
- Cuba R. Co. v. CommissionerUnited States Tax Court · 1947
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