Legal Opinion

Miles Production Co. v. Commissioner

United States Tax Court

Decided April 2, 1991No. Docket No. 16543-88Published

The Commissioner determined deficiencies in petitioner's windfall profit tax for calendar years 1981 and 1982. Petitioner filed Federal income tax returns for the taxable years ended June 30, 1981, June 30, 1982, and June 30, 1983. It did not file annual windfall profit tax returns.

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The Commissioner determined deficiencies in petitioner's windfall profit tax for calendar years 1981 and 1982. Petitioner filed Federal income tax returns for the taxable years ended June 30, 1981, June 30, 1982, and June 30, 1983. It did not file annual windfall profit tax returns. Petitioner claimed overpayments of windfall profit tax as credits against its income tax liabilities on its income tax returns, amended income tax return, and claims for refund based upon application of the net income limitation. Petitioner and the Commissioner executed Special Consents to Extend the Time to…

1Opinion of the Court

Miles Production Company, Petitioner v. Commissioner of Internal Revenue, Respondent

Miles Production Co. v. Commissioner

Docket No. 16543-88

United States Tax Court

96 T.C. 595; 1991 U.S. Tax Ct. LEXIS 28; 96 T.C. No. 22;

April 2, 1991, Filed

The Commissioner determined deficiencies in petitioner's windfall profit tax for calendar years 1981 and 1982. Petitioner filed Federal income tax returns for the taxable years ended June 30, 1981, June 30, 1982, and June 30, 1983. It did not file annual windfall profit tax returns. Petitioner claimed overpayments of windfall profit tax as credits against its…

2Cases cited12 opinions

  1. Woods v. CommissionerUnited States Tax Court · 1989
  2. Sanderling, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1978
  3. Sanderling, Inc. v. CommissionerUnited States Tax Court · 1976
  4. Page v. CommissionerUnited States Tax Court · 1986
  5. Transco Exploration Co. v. CommissionerUnited States Tax Court · 1990

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