Weather-Seal Mfg. Co. v. Commissioner
United States Tax Court
Deduction -- Wages Paid in Violation of the Emergency Price Control Act of 1942. -- On its tax returns petitioner included as a part of the cost of goods sold the amount of wages paid to certain employees engaged in its manufacturing plant. The National War Labor Board determined that $ 5,000 of the wages so paid was in violation of the wage stabilization laws and shall be disallowed by the Commissioner in calculating costs and deductions for income tax purposes.
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Deduction -- Wages Paid in Violation of the Emergency Price Control Act of 1942. -- On its tax returns petitioner included as a part of the cost of goods sold the amount of wages paid to certain employees engaged in its manufacturing plant. The National War Labor Board determined that $ 5,000 of the wages so paid was in violation of the wage stabilization laws and shall be disallowed by the Commissioner in calculating costs and deductions for income tax purposes. Pursuant thereto and also his own regulations, the Commissioner disallowed the item of $ 5,000 as a deduction in computing net…
1Opinion of the Court
OPINION.
Tietjens, Judge;
The Commissioner has determined deficiencies in petitioner’s income and excess profits tax liability for the fiscal years ended May 31,1945 and 1946, as follows:
1945 1946
Income tax_ — $590. 31
Excess profits tax_$3,600 2,238. 72
With respect to the determination for the fiscal year 1945, petitioner concedes that respondent properly disallowed $4,375 of the amount claimed as a deduction for capital stock tax.
The petitioner’s assignments of error raise two questions: First, whether in determining petitioner’s taxable net income for each of the fiscal years 1945 and 1946,…
2Cases cited7 opinions
- Sullenger v. CommissionerUnited States Tax Court · 1948
- Jerry Rossman Corporation v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1949
- Majestic Securities Corp. v. Commissioner of Int. Rev.Court of Appeals for the Eighth Circuit · 1941
- Lilly v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1951
- National Brass Works, Inc. v. CommissionerUnited States Tax Court · 1951
2 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Fuller v. CommissionerUnited States Tax Court · 1953
- Max Sobel Wholesale Liquors v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
- Hofferbert, Collector of Internal Revenue v. Anderson Oldsmobile, IncCourt of Appeals for the Fourth Circuit · 1952
- Weather-Seal Manufacturing Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1952
- Johnson v. CommissionerUnited States Tax Court · 1964
18 more not listed; retrieve them via the Exa API.