W. C. Mitchell Co. v. Commissioner
United States Board of Tax Appeals
1. Where tax liability for a given year has been determined on the basis of a petitioner's agreed net income and the parties have entered into a closing agreement under the provisions of section 606 of the Revenue Act of 1928, the petitioner may prove a net loss in such year for the purpose of reducing its tax liability in a subsequent year. 2. In the circumstances of this proceeding, where stock is sold by a corporation and a promissory note is taken therefor, the…
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1. Where tax liability for a given year has been determined on the basis of a petitioner's agreed net income and the parties have entered into a closing agreement under the provisions of section 606 of the Revenue Act of 1928, the petitioner may prove a net loss in such year for the purpose of reducing its tax liability in a subsequent year. 2. In the circumstances of this proceeding, where stock is sold by a corporation and a promissory note is taken therefor, the corporation has an equitable lien against such stock which is not affected by the running of the statute of limitations against…
1Opinion of the Court
W. C. MITCHELL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
W. C. Mitchell Co. v. Commissioner
Docket No. 49986.
United States Board of Tax Appeals
27 B.T.A. 645; 1933 BTA LEXIS 1342;
January 31, 1933, Promulgated
1. Where tax liability for a given year has been determined on the basis of a petitioner's agreed net income and the parties have entered into a closing agreement under the provisions of section 606 of the Revenue Act of 1928, the petitioner may prove a net loss in such year for the purpose of reducing its tax liability in a subsequent year.
2. In the circumstances…
2Cases cited9 opinions
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- Geo. A. Hormel Company v. First National BankSupreme Court of Minnesota · 1927
- United Cigarette Machine Co. v. BrownSupreme Court of Virginia · 1916
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