Altschul's, Inc. v. Commissioner
United States Tax Court
Petitioner, which kept its accounts and filed its returns on an accrual basis, accrued as liabilities for its fiscal year ended January 31, 1943, income taxes and excess profits taxes for that year which were paid in the following year, and accrued as an asset in 1943 the post-war refund credit provided by section 780, I. R. C. These accruals were reflected in its accumulated earnings and profits as of January 31, 1943. Petitioner used the invested capital method in…
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Petitioner, which kept its accounts and filed its returns on an accrual basis, accrued as liabilities for its fiscal year ended January 31, 1943, income taxes and excess profits taxes for that year which were paid in the following year, and accrued as an asset in 1943 the post-war refund credit provided by section 780, I. R. C. These accruals were reflected in its accumulated earnings and profits as of January 31, 1943. Petitioner used the invested capital method in computing its excess profits tax credit for the fiscal year 1944. Respondent eliminated from petitioner's "accumulated earnings…
1Opinion of the Court
OPINION.
Kern, Judge:
The Commissioner determined a deficiency in petitioner’s excess profits tax for the fiscal year ended January 31, 1944, in the amount of $516.10. The single question relates to the time for the accrual of the post-war refund provided by section 780 of the Internal Revenue Code.
The facts have been wholly stipulated, and we find them to be as stipulated.
Petitioner is a Virginia corporation, with its principal place of business at Norfolk. It filed its excess profits .tax return for its fiscal year ended January 31, 1944, with the collector of internal revenue for the…
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