San Francisco Stevedoring Co. v. Commissioner
United States Tax Court
1. Income -- Accrual. -- An item of $ 5,499.24 did not accrue as income of the year 1939. 2. Excess Profits Tax -- Excess Profits Credit Carry-over. -- The provisions of section 721 do not apply for the purpose of computing the excess profits carry-over of 1941 to 1942.
1Opinion of the Court
OPINION.
Murdock, Judge'.
The Commissioner determined a deficiency of $2,928.81 in the petitioner’s excess profits tax for the calendar year 1942. The first issue for decision is whether $5,499.24 should have been accrued as income for the year 1939, thus increasing the income of the base period. The facts have been stipulated and the stipulation is adopted as the findings of fact.
The petitioner is a California corporation. Its return for 1942 was filed with the collector of internal revenue for the northern district of California.
The petitioner kept its books and made its returns at all times…
2Cases cited5 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Continental Tie & Lumber Co. v. United StatesSupreme Court of the United States · 1932
- United States v. Safety Car Heating & Lighting Co.Supreme Court of the United States · 1936
- Estate of Putnam v. CommissionerSupreme Court of the United States · 1945
3Cited by28 opinions
- Fifth Ave. Coach Lines,Inc. v. CommissionerUnited States Tax Court · 1959
- Long Poultry Farms, Incorporated v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957
- Commercial Solvents Corp. v. CommissionerUnited States Tax Court · 1964
- Schlude v. CommissionerUnited States Tax Court · 1959
- Smith v. CommissionerUnited States Tax Court · 1967
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