Morrisdale Coal Mining Co. v. Commissioner
United States Tax Court
Held, respondent's action in adjusting petitioner's income tax liability and determining a deficiency therein, such adjustment and determination being based upon a prior decision of this Court wherein petitioner was granted a refund of excess profits tax under section 721, Internal Revenue Code, sustained.
1Opinion of the Court
OPINION.
Van Fossan, Judge:
At the outset, petitioner challenges the propriety of respondent’s action in effecting an adjustment of the credit allowed it under section 26 (e)1 of the Code. Specifically, petitioner contends that section 721 of the Internal'Revenue Code provides for relief from excess profits tax after all other issues are disposed of, and that it is so limited and does not comprehend any adjustment to income tax liability as a result of such relief. In reply to the argument, respondent points to section 26 (e), supra., itself, and maintains that such section clearly authorizes…
2Cases cited4 opinions
- Uni-Term Stevedoring Co. v. CommissionerUnited States Tax Court · 1944
- Morrisdale Coal Mining Co. v. CommissionerUnited States Tax Court · 1952
- Southern Sportswear Co. v. CommissionerUnited States Tax Court · 1948
- Hadley Furniture Co. v. United StatesDistrict Court, D. Massachusetts · 1949
3Cited by9 opinions
- Ambassador Hotel Co. v. CommissionerUnited States Tax Court · 1959
- Morrisdale Coal Mining Co. v. United StatesUnited States Court of Claims · 1956
- Merrimac Hat Corp. v. CommissionerUnited States Tax Court · 1959
- Mutual Shoe Co. v. CommissionerUnited States Tax Court · 1955
- Polaroid Corp. v. CommissionerUnited States Tax Court · 1959
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