Solon Decorating Co. v. Commissioner

These petitions to review decisions of the Tax Court were consolidated here for briefing, hearing and decision. Identical questions are presented in all three cases: Did the Defense Production Act of 1950, 50 U.S.C.A.Appendix, § 2061 et seq. provide for the disallowance for income tax purposes of wage payments made by taxpayers in violation of the wage stabilization provisions of the Act and certified to the Commissioner for disallowance? If it did so provide, did the 1950 Act impose a tax on capital in violation of Article I, Section 9, of the Constitution rather than a tax on income within…