Mills, Inc. v. Commissioner
United States Tax Court
Petitioner, in the computation of its personal holding company tax liability for the year 1949, took a deduction under section 505 (a) (1), I. R. C. 1939, of $ 49,823.24 paid in that year, which sum was the net deficiency in petitioner's excess profits taxes for the years 1944 and 1945. Held, respondent was correct in disallowing the deduction under Wm. J. Lemp Brewing Co., 18 T. C. 586, 600, adopting the rule of Commissioner v. Clarion Oil Co., 148 F. 2d 671.
1Opinion of the Court
Mills, Incorporated, Petitioner, v. Commissioner of Internal Revenue, Respondent
Mills, Inc. v. Commissioner
Docket No. 54305
United States Tax Court
27 T.C. 635; 1957 U.S. Tax Ct. LEXIS 286;
January 8, 1957, Filed
Decision will be entered under Rule 50.
Petitioner, in the computation of its personal holding company tax liability for the year 1949, took a deduction under section 505 (a) (1), I. R. C. 1939, of $ 49,823.24 paid in that year, which sum was the net deficiency in petitioner's excess profits taxes for the years 1944 and 1945. Held, respondent was correct in disallowing the deduction under…
2Cases cited8 opinions
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- Commissioner of Internal Revenue v. Clarion Oil Co.Court of Appeals for the D.C. Circuit · 1945
- Clarion Oil Co. v. CommissionerUnited States Tax Court · 1943
- De Soto Securities Company v. Commission of Internal RevenueCourt of Appeals for the Seventh Circuit · 1956
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