Welch Grape Juice Co. v. Commissioner
United States Tax Court
Where petitioner seeks to exclude a number of deductions in the computation of its base period net income and the Commissioner denies the propriety of such exclusion, the petitioner, after amending its petition, may establish by evidence its right to such exclusion in the last two years of said base period and accede to the Commissioner's rejection thereof in the first two years, where the exclusions of the last two years of the base period fall in a class differing from…
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Where petitioner seeks to exclude a number of deductions in the computation of its base period net income and the Commissioner denies the propriety of such exclusion, the petitioner, after amending its petition, may establish by evidence its right to such exclusion in the last two years of said base period and accede to the Commissioner's rejection thereof in the first two years, where the exclusions of the last two years of the base period fall in a class differing from that of the exclusions originally claimed for the first two years thereof, even though the petitioner procures a tax…
1Opinion of the Court
OPINION.
Hablan, Judge:
In its excess profits tax return for the year ended August 31,1942, petitioner claimed certain adjustments for abnormal deductions under sec. 711 (b) (1) (J) of the Internal Revenue Code applicable to its base period years ended August 31, 1937, 1938, 1939, and 1940. These claimed adjustments were all disallowed by the respondent.
In its amended petition the petitioner alleges that, in computing its base period net income, the respondent erred in failing to allow the following adjustments as increasing excess profits net income for the base period years indicated:
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2Cases cited3 opinions
- R. C. Harvey Co. v. CommissionerUnited States Tax Court · 1945
- Colson Corp. v. CommissionerUnited States Tax Court · 1945
- Fain Drilling Co. v. CommissionerUnited States Tax Court · 1947
3Cited by6 opinions
- George J. Meyer Malt & Grain Corp. v. CommissionerUnited States Tax Court · 1948
- Myers v. CommissionerUnited States Tax Court · 1949
- Corn Prods. Ref. Co. v. CommissionerUnited States Tax Court · 1952
- George J. Meyer Malt & Grain Corp. v. CommissionerUnited States Tax Court · 1948
- Myers v. CommissionerUnited States Tax Court · 1949
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