National Lead Co. v. Commissioner
United States Tax Court
1. The petitioner by letter dated March 4, 1952, addressed to the respondent, elected, pursuant to section 22(d)(6)(F) of the Internal Revenue Code of 1939, to replace its inventory of zinc which was involuntarily liquidated in its taxable year 1950. Thereafter, on September 24, 1952, the respondent promulgated regulations implementing section 22(d)(6)(F) in which it was provided that elections to replace inventories involuntarily liquidated in taxable years beginning after…
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1. The petitioner by letter dated March 4, 1952, addressed to the respondent, elected, pursuant to section 22(d)(6)(F) of the Internal Revenue Code of 1939, to replace its inventory of zinc which was involuntarily liquidated in its taxable year 1950. Thereafter, on September 24, 1952, the respondent promulgated regulations implementing section 22(d)(6)(F) in which it was provided that elections to replace inventories involuntarily liquidated in taxable years beginning after June 30, 1950, and prior to March 1, 1952, might be made at any time not later than December 15, 1952. On December 12,…
1Opinion of the Court
Atkins, Judge:
The respondent determined a deficiency in income tax for the calendar year 1952 in the amount of $928,399.50. Certain issues have been disposed of by agreement of the parties. The principal issues remaining for decision are (1) whether the petitioner could effectively revoke or withdraw an election previously made by it under section 22(d) (6) of the Internal Eevenue Code of 1939 to replace a Lifo zinc inventory involuntarily liquidated in 1950, where the attempted revocation or withdrawal was made prior to the expiration of the time for making the initial election; and (2)…
2Cases cited25 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Higgins v. SmithSupreme Court of the United States · 1940
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Corliss v. BowersSupreme Court of the United States · 1930
- Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
20 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Riss v. CommissionerUnited States Tax Court · 1971
- Henry C. Beck Builders, Inc. v. CommissionerUnited States Tax Court · 1964
- Matheson v. CommissionerUnited States Tax Court · 1980
- National Lead Company v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1964
- Lomas Santa Fe, Inc. v. CommissionerUnited States Tax Court · 1980
14 more not listed; retrieve them via the Exa API.