Geometric Stamping Co. v. Commissioner
United States Tax Court
Petitioner having changed to a "direct costing" method of reporting its income and having consistently filed reports on that basis and respondent having accepted such reporting as correct for the year 1948, held, petitioner's use of such method of reporting for the tax year 1950 was proper, notwithstanding that it continued to keep its books on an "absorption method" of accounting.
1Opinion of the Court
OPINION.
Offer, Judge:
Petitioner’s main reliance is upon a supposed estop-pel directed against respondent by the conduct of his representatives. While in the view that we take it is unnecessary to pass directly upon this contention it may not be amiss to point out that in addition to the general difficulty of creating an estoppel against respondent as a representative of the sovereign, James Couzens, 11 B. T. A. 1040, 1151, there is in this case reasonably clear evidence that petitioner did not rely upon the conduct of which it now complains. By the time any clear-cut attitude on respondent’s…
2Cases cited8 opinions
- Niles Bement Pond Co. v. United StatesSupreme Court of the United States · 1930
- Atlantic C. L. R. Co. v. CommissionerUnited States Tax Court · 1944
- Gus Blass Co. v. CommissionerUnited States Tax Court · 1947
- National Airlines, Inc. v. CommissionerUnited States Tax Court · 1947
- Fowler Bros. & Cox, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1943
3 more not listed; retrieve them via the Exa API.
3Cited by48 opinions
- Madison Gas & Electric Co. v. CommissionerUnited States Tax Court · 1979
- Coors v. CommissionerUnited States Tax Court · 1973
- Ft. Howard Paper Co. v. CommissionerUnited States Tax Court · 1967
- FPL Group, Inc. v. CommissionerUnited States Tax Court · 2000
- Photo-Sonics, Inc. v. CommissionerUnited States Tax Court · 1964
43 more not listed; retrieve them via the Exa API.