Legal Opinion

Tecumseh Coal Corp. v. Commissioner

United States Tax Court

Decided October 10, 1951No. Docket No. 30746Published

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

Tecumseh Coal Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Tecumseh Coal Corp. v. Commissioner

Docket No. 30746

United States Tax Court

17 T.C. 636; 1951 U.S. Tax Ct. LEXIS 58;

October 10, 1951, Promulgated

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…

Also in this document: Dissent.

2Cases cited8 opinions

  1. Stone v. WhiteSupreme Court of the United States · 1937
  2. Mutual Lumber Co. v. CommissionerUnited States Tax Court · 1951
  3. Uni-Term Stevedoring Co. v. CommissionerUnited States Tax Court · 1944
  4. American Coast Line, Inc. v. CommissionerUnited States Tax Court · 1946
  5. American Coast Line v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1947

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