Green Spring Dairy, Inc. v. Commissioner
United States Tax Court
Held, pursuant to the pleadings and respondent's 90-day letters, the Court has jurisdiction of deficiencies determined by respondent as well as relief sought by petitioner under section 722, and orders will be entered finding deficiencies thus determined where they were not otherwise contested.
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Held, pursuant to the pleadings and respondent's 90-day letters, the Court has jurisdiction of deficiencies determined by respondent as well as relief sought by petitioner under section 722, and orders will be entered finding deficiencies thus determined where they were not otherwise contested. Held, further, such orders may include a finding of deficiency attributable to excess profits taxes deferred under section 710 (a) (5), in view of the fact that the section 722 issue has already been adjudicated.
1Opinion of the Court
SUPPLEMENTAL OPINION.
Raum, Judge:
Pursuant to the opinion previously rendered herein (18 T. C. 217), decisions have been entered to the effect that petitioner is not entitled to relief under section 722 of the Internal Revenue Code. Respondent has filed motions that the decisions be modified, by adding that there are deficiencies in excess profits taxes for the years 1940-1945, inclusive,. in the amounts of $1,342.60, $3,868.98, $10,145.37, $7,002.55, $39,515.99, and $2,145.67, respectively. These amounts were determined as deficiencies by the Commissioner, and notices of such deficiencies…
2Cases cited3 opinions
- California Vegetable Concentrates, Inc. v. CommissionerUnited States Tax Court · 1948
- Ideal Packing Co. v. CommissionerUnited States Tax Court · 1947
- Tecumseh Coal Corp. v. CommissionerUnited States Tax Court · 1951
3Cited by14 opinions
- Green Spring Dairy, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
- Eversole v. CommissionerUnited States Tax Court · 1966
- Empire Constr. Co. v. CommissionerUnited States Tax Court · 1959
- Schenley Industries, Inc. v. CommissionerUnited States Tax Court · 1964
- Calvert Iron Works, Inc. v. CommissionerUnited States Tax Court · 1956
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