Ambassador Hotel Co. v. Commissioner
United States Tax Court
The Commissioner determined a deficiency in petitioner's income tax for the year 1944, which resulted by operation of law from the adjustment of said corporation's excess profits tax for the same taxable year, in accordance with a prior decision of this Court. The petitioner pleaded in defense, only the general statute of limitation under section 275 of the 1939 Code.
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The Commissioner determined a deficiency in petitioner's income tax for the year 1944, which resulted by operation of law from the adjustment of said corporation's excess profits tax for the same taxable year, in accordance with a prior decision of this Court. The petitioner pleaded in defense, only the general statute of limitation under section 275 of the 1939 Code. Held: 1. That assessment of the deficiency is not prevented or barred, because of the applicability of section 3807 of the 1939 Code (relating to period of limitation in case of related taxes under chapter 1 and chapter 2 of…
1Opinion of the Court
Pierce, Judge:
The respondent determined a deficiency of $33,-290.61 in the income tax of the petitioner. Ambassador Hotel Company of Los Angeles, for its taxable year ended January 31,1944.
Said deficiency is based on the increase in petitioner’s income tax as previously returned and determined, which increase resulted, by operation of the applicable statutes, from the adjustment of petitioner’s related excess profits tax for the same taxable year in accordance with a previous opinion and final decision of this Court. The deficiency and the basis thereof are explained in the notice of…
2Cases cited9 opinions
- Freuler v. HelveringSupreme Court of the United States · 1934
- Freshman v. AtkinsSupreme Court of the United States · 1925
- Booth v. FletcherCourt of Appeals for the D.C. Circuit · 1938
- Latta v. Western Inv. Co.Court of Appeals for the Ninth Circuit · 1949
- Commissioner of Internal Revenue v. Michael Shapiro and Rae ShapiroCourt of Appeals for the Seventh Circuit · 1960
4 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Perpetual Bldg. & Loan Asso. v. CommissionerUnited States Tax Court · 1960
- Ambassador Hotel Company of Los Angeles, a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
- Perkins v. CommissionerUnited States Tax Court · 1961
- Gill v. CommissionerUnited States Tax Court · 1961
- Merrimac Hat Corp. v. CommissionerUnited States Tax Court · 1959
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