Williamson v. Commissioner
United States Tax Court
Petitioners filed their income tax returns for the short period from March 1, 1946, to December 31, 1946, in the process of changing from a fiscal year to a calendar year basis. Petitioners did not request or obtain the permission of the Commissioner to make the change, but the Commissioner accepted the returns and determined deficiencies based upon the short period. The record is silent concerning whether petitioners actually made changes in their accounting periods.
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Petitioners filed their income tax returns for the short period from March 1, 1946, to December 31, 1946, in the process of changing from a fiscal year to a calendar year basis. Petitioners did not request or obtain the permission of the Commissioner to make the change, but the Commissioner accepted the returns and determined deficiencies based upon the short period. The record is silent concerning whether petitioners actually made changes in their accounting periods. The Commissioner based his deficiencies upon a computation of the tax in accordance with the provisions of section 47 (c) (1),…
1Opinion of the Court
Andrew John Williamson, Petitioner, v. Commissioner of Internal Revenue, Respondent. Mary M. J. Williamson, Petitioner, v. Commissioner of Internal Revenue, Respondent
Williamson v. Commissioner
Docket Nos. 39278, 39279
United States Tax Court
22 T.C. 684; 1954 U.S. Tax Ct. LEXIS 163;
June 29, 1954, Filed. June 29, 1954, Filed
Decisions will be entered for the respondent.
Petitioners filed their income tax returns for the short period from March 1, 1946, to December 31, 1946, in the process of changing from a fiscal year to a calendar year basis. Petitioners did not request or obtain the permission…
2Cases cited7 opinions
- Helvering v. Brooklyn City R. Co.Court of Appeals for the Second Circuit · 1934
- Visintainer v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1951
- Linen Thread Co. v. CommissionerUnited States Tax Court · 1950
- Visintainer v. CommissionerUnited States Tax Court · 1949
- Bass v. StimsonUnited States Tax Court · 1953
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