Sommerfeld Machine Co. v. Commissioner
United States Tax Court
The Court has jurisdiction to hear petitioner's claim for relief under section 721, Internal Revenue Code, on a petition for a redetermination of deficiencies in excess profits taxes, and the denial of a claim for refund of excess profits taxes is not a prerequisite to such jurisdiction.
1Opinion of the Court
OPINION.
Turner, Judge'.
The respondent determined deficiencies in excess profits tax of $34,333.63, $78,922.56, $73,466.43, and $24,614.14 against petitioner for its taxable years ended December 31, 1941, 1942, 1943, and 1944.
The only question now submitted is whether in this proceeding the Court has jurisdiction to consider the applicability of section 721 of the Internal Revenue Code.
Petitioner is a Pennsylvania corporation, with its principal place of business in Braddock, Pennsylvania. It filed the returns for the years involved with the collector of internal revenue for the twenty-third…
2Cases cited6 opinions
- Blum Folding Paper Box Co. v. CommissionerUnited States Tax Court · 1945
- Pioneer Parachute Co. v. CommissionerUnited States Tax Court · 1944
- Uni-Term Stevedoring Co. v. CommissionerUnited States Tax Court · 1944
- American Coast Line, Inc. v. CommissionerUnited States Tax Court · 1946
- E. B. & A. C. Whiting Co. v. CommissionerUnited States Tax Court · 1948
1 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Nubar v. CommissionerUnited States Tax Court · 1949
- Curtis v. CommissionerUnited States Tax Court · 1949
- Edgewater Steel Co. v. CommissionerUnited States Tax Court · 1955
- Curtis v. CommissionerUnited States Tax Court · 1949
- Edgewater Steel Co. v. CommissionerUnited States Tax Court · 1955
2 more not listed; retrieve them via the Exa API.