Denman Tire & Rubber Co. v. Commissioner
United States Tax Court
1. Petitioner was organized to take over as of October 1, 1937, pursuant to a revised plan of reorganization, the assets and some of the liabilities of its predecessor corporation. Among the liabilities was an obligation of $ 144,572.49 owing to the United States Government for manufacturers' excise taxes incurred by petitioner's predecessor. Petitioner executed a promissory note in payment of this indebtedness and executed a mortgage to secure the payment of the note.
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1. Petitioner was organized to take over as of October 1, 1937, pursuant to a revised plan of reorganization, the assets and some of the liabilities of its predecessor corporation. Among the liabilities was an obligation of $ 144,572.49 owing to the United States Government for manufacturers' excise taxes incurred by petitioner's predecessor. Petitioner executed a promissory note in payment of this indebtedness and executed a mortgage to secure the payment of the note. As of May 23, 1941, this obligation was reduced to $ 125,500. In November, 1941, this liability was settled for $ 50,000. On…
1Opinion of the Court
Black, Judge-.
This proceeding involves deficiencies in excess
profits tax for the calendar years 1942 and 1943 in the respective amounts of $39,959.89 and $186,944.91. The deficiencies are due to numerous adjustments to petitioner’s net income. Many of these adjustments are not contested by petitioner. Respondent’s adjustments which result in the major portion of the deficiency- were explained in a statement attached to the deficiency notice as follows:
19 4& (c) In your return for the year 1941, you reported a net loss of $4,990.87. You contend that said net loss should be increased by…
2Cases cited10 opinions
- Commissioner v. JacobsonSupreme Court of the United States · 1949
- J. E. Riley Investment Co. v. CommissionerSupreme Court of the United States · 1940
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- William Leveen Corp. v. CommissionerUnited States Tax Court · 1944
- Green Bay Lumber Co. v. CommissionerUnited States Tax Court · 1944
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3Cited by32 opinions
- Taylor v. CommissionerUnited States Tax Court · 1977
- Dougherty v. CommissionerUnited States Tax Court · 1973
- Magill v. CommissionerUnited States Tax Court · 1978
- American Air Filter Co. v. CommissionerUnited States Tax Court · 1983
- Montgomery v. CommissionerUnited States Tax Court · 1975
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