Houston Textile Co. v. Commissioner
United States Tax Court
Petitioner is a Texas corporation which was dissolved October 31, 1945, and under the applicable statutes has a taxable year of less than 12 months, to wit, August 1 to October 31, 1945. It elected to have its excess profits tax for the period in question computed under section 711 (a) (3) (B) of the Internal Revenue Code and its right to do so is not in dispute.
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Petitioner is a Texas corporation which was dissolved October 31, 1945, and under the applicable statutes has a taxable year of less than 12 months, to wit, August 1 to October 31, 1945. It elected to have its excess profits tax for the period in question computed under section 711 (a) (3) (B) of the Internal Revenue Code and its right to do so is not in dispute. Under such computation its adjusted excess profits net income was $ 81,764.17. Petitioner's actual net income for the three-month period involved was $ 52,362.60. In his determination of a deficiency in petitioner's income tax for…
1Opinion of the Court
OPINION.
Black, Judge:
The Commissioner has determined a deficiency in petitioner’s income tax for the taxable year August 1 to October 31, 1945, in the sum of $6,005.76. The petitioner assigns the following errors in contest of this determination:
1. The Commissioner erred in his method of computation of the credit to be allowed petitioner under Section 26 (e) of the Internal Revenue Code.
2. The Commissioner erred in refusing to allow petitioner in the determination of its normal tax net income and surtax net income a credit of an amount equal to its adjusted excess-profits net income (as…
2Cases cited3 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- West End Furniture Co. v. CommissionerUnited States Tax Court · 1946
- Pepsi Cola Co. v. CommissionerUnited States Tax Court · 1945
3Cited by2 opinions
- Houston Textile Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1949
- Houston Textile Co. v. CommissionerUnited States Tax Court · 1948