Dale Distributing Co. v. Commissioner
United States Tax Court
Taxpayer filed timely applications for relief under section 722 for 1943 claiming the right to the benefits of unused excess profits credit carryovers from 1941 and 1942 based on CABPNI's.
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Taxpayer filed timely applications for relief under section 722 for 1943 claiming the right to the benefits of unused excess profits credit carryovers from 1941 and 1942 based on CABPNI's. The Commissioner proposed tentative CABPNI's and the taxpayer was advised by a revenue agent to file amended applications claiming the benefits of unused excess profits credit carrybacks and carryovers resulting from such CABPNI's, whereupon taxpayer filed timely amended applications and refund claims asserting its right to the benefits of unused excess profits credit carrybacks from 1944 to 1942 and from…
1Opinion of the Court
Dale Distributing Company, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Dale Distributing Co. v. Commissioner
Docket No. 58969
United States Tax Court
29 T.C. 799; 1958 U.S. Tax Ct. LEXIS 267;
January 31, 1958, Filed
Decision will be entered for the respondent.
Taxpayer filed timely applications for relief under section 722 for 1943 claiming the right to the benefits of unused excess profits credit carryovers from 1941 and 1942 based on CABPNI's. The Commissioner proposed tentative CABPNI's and the taxpayer was advised by a revenue agent to file amended applications claiming the…
2Cases cited15 opinions
- United States v. Memphis Cotton Oil Co.Supreme Court of the United States · 1933
- Angelus Milling Co. v. CommissionerSupreme Court of the United States · 1945
- United States v. Garbutt Oil Co.Supreme Court of the United States · 1938
- Smale & Robinson, Inc. v. United StatesDistrict Court, S.D. California · 1954
- H. Fendrich, Inc. v. CommissionerUnited States Tax Court · 1955
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