Tecumseh Coal Corp. v. Commissioner
United States Tax Court
By proper notice respondent allowed in part and disallowed in part petitioner's claim for relief under section 722, I. R. C. In the same notice respondent determined deficiencies in income tax resulting solely from a decrease in excess profits tax credit due to the partial allowance of petitioner's claim for relief.
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By proper notice respondent allowed in part and disallowed in part petitioner's claim for relief under section 722, I. R. C. In the same notice respondent determined deficiencies in income tax resulting solely from a decrease in excess profits tax credit due to the partial allowance of petitioner's claim for relief. The only error alleged in the petition with reference to the deficiencies in income tax is that they "should not be assessed prior to a final determination of the [section 722] issue * * *." Respondent moved that petition be dismissed for lack of proper prosecution insofar as it…
1Opinion of the Court
OPINION.
Kern, Judge:
This proceeding is here on a motion by respondent to dismiss for lack of proper prosecution, in so far as it relates to deficiencies in income tax for 1942, 1943, and 1944, in the aggregate amount of $171,213.76. The motion also asks the Court to enter an order finding deficiencies in income tax in the amounts determined by respondent.
The notice of deficiency and partial disallowance of section 722 relief, dated June 30,1950, determined income tax deficiencies, as above set forth, in the aggregate amount of $171,213.76, and further determined that petitioner was entitled…
2Cases cited5 opinions
- Stone v. WhiteSupreme Court of the United States · 1937
- Mutual Lumber Co. v. CommissionerUnited States Tax Court · 1951
- Uni-Term Stevedoring Co. v. CommissionerUnited States Tax Court · 1944
- Doylestown & Easton Motor Coach Co. v. CommissionerUnited States Tax Court · 1947
- Hadley Furniture Co. v. United StatesDistrict Court, D. Massachusetts · 1949
3Cited by3 opinions
- Green Spring Dairy, Inc. v. CommissionerUnited States Tax Court · 1952
- Green Spring Dairy, Inc. v. CommissionerUnited States Tax Court · 1952
- Tecumseh Coal Corp. v. CommissionerUnited States Tax Court · 1951