Ideal Packing Co. v. Commissioner
United States Tax Court
The respondent mailed combined notices of deficiency in excess profits tax and of disallowance of a claim for refund under section 722 of the Internal Revenue Code.
Read the full summary
The respondent mailed combined notices of deficiency in excess profits tax and of disallowance of a claim for refund under section 722 of the Internal Revenue Code. In the petition filed, the amount of the deficiency was stated as being in controversy, but the petition contained no allegations of fact or error with respect thereto, the only allegations of error and supporting facts being directed to the relief claimed under section 722. Respondent has moved that the proceeding be dismissed for failure to prosecute in so far as it relates to the deficiency. Held, that respondent's motion is…
1Opinion of the Court
OPINION.
Turner, Judge:
The respondent determined deficiencies in excess profits tax in the respective amounts of $2,025 and $15,675.47 against the petitioner for its fiscal years ended October 31,1943 and 1944, and in the notice of deficiency also stated the disallowance of petitioner’s claim for relief under section 722 of the Internal Revenue Code for the said years. On July 26, 1946, the petitioner filed its petition herein, the only claim of error being that the respondent erroneously determined that petitioner had not established its right to relief under section 722 of the Internal…
2Cases cited2 opinions
- Uni-Term Stevedoring Co. v. CommissionerUnited States Tax Court · 1944
- American Coast Line, Inc. v. CommissionerUnited States Tax Court · 1946
3Cited by12 opinions
- Mutual Lumber Co. v. CommissionerUnited States Tax Court · 1951
- United States v. Koppers Co.Supreme Court of the United States · 1955
- Martin Weiner Corp. v. CommissionerUnited States Tax Court · 1954
- Green Spring Dairy, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
- West Flagler Amusement Co. v. CommissionerUnited States Tax Court · 1954
7 more not listed; retrieve them via the Exa API.