Joan Carol Corp. v. Commissioner
United States Tax Court
Petitioner, a personal holding company, filing its Federal tax returns on a cash receipts and disbursements basis, in computing subchapter A net income, deducted the amount of income tax shown on its Federal income tax return for the taxable year. Held, the Commissioner did not err in allowing deduction of only the amount of Federal income tax paid during the taxable year.
1Opinion of the Court
OPINION.
Disney, Judge:
This case involves personal holding company surtax liability for the fiscal year ended May 31, 1946. Deficiency was determined in the amount of $17,813.58. The sole question presented is whether the taxpayer, upon the cash basis, may, in computing its sub-chapter A net income, deduct Federal income taxes accrued for the taxable year but not paid in that year. The petitioner filed its return for the taxable year with the collector for the second district of New York.
All facts have been stipulated, as follows:(a) Petitioner is a corporation organized under the laws of the…
2Cases cited8 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Brewster v. GageSupreme Court of the United States · 1930
- Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
- Fawcus MacHine Co. v. United StatesSupreme Court of the United States · 1931
- Reinecke v. SmithSupreme Court of the United States · 1933
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3Cited by14 opinions
- De Soto Securities Company v. Commission of Internal RevenueCourt of Appeals for the Seventh Circuit · 1956
- Arc Realty Co. v. CommissionerUnited States Tax Court · 1960
- De Soto Sec. Co. v. CommissionerUnited States Tax Court · 1955
- Wm. J. Lemp Brewing Co. v. CommissionerUnited States Tax Court · 1952
- Mariani Frozen Foods, Inc. v. CommissionerUnited States Tax Court · 1983
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