Ciba Pharmaceutical Products, Inc. v. Commissioner
United States Tax Court
1. Held, petitioner is not entitled to excess profits tax relief under section 722(b)(4), I.R.C. 1939, in excess of that allowed by the respondent. 2. Held, further, petitioner is precluded by section 143(f), I.R.C. 1939, from claiming an overpayment of taxes actually withheld from the 1944 royalty payments made by it to its foreign parent. 3. Held, further, this Court does not have jurisdiction over petitioner's alleged overpayment of taxes withheld from the 1945 royalty…
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1. Held, petitioner is not entitled to excess profits tax relief under section 722(b)(4), I.R.C. 1939, in excess of that allowed by the respondent. 2. Held, further, petitioner is precluded by section 143(f), I.R.C. 1939, from claiming an overpayment of taxes actually withheld from the 1944 royalty payments made by it to its foreign parent. 3. Held, further, this Court does not have jurisdiction over petitioner's alleged overpayment of taxes withheld from the 1945 royalty payments made by it to its foreign parent, since respondent did not determine any deficiency in petitioner's income tax…
1Opinion of the Court
Ciba Pharmaceutical Products, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Ciba Pharmaceutical Products, Inc. v. Commissioner
Docket No. 45364
United States Tax Court
35 T.C. 337; 1960 U.S. Tax Ct. LEXIS 17;
November 25, 1960, Filed
Decision will be entered under Rule 50.
1. Held, petitioner is not entitled to excess profits tax relief under section 722(b)(4), I.R.C. 1939, in excess of that allowed by the respondent.
2. Held, further, petitioner is precluded by section 143(f), I.R.C. 1939, from claiming an overpayment of taxes actually withheld from the 1944 royalty payments made…
Also in this document: Concurrence.
2Cases cited21 opinions
- Avey Drilling Machine Co. v. CommissionerUnited States Tax Court · 1951
- Mutual Lumber Co. v. CommissionerUnited States Tax Court · 1951
- Dial v. CommissionerUnited States Tax Court · 1955
- Homer Laughlin China Co. v. CommissionerUnited States Tax Court · 1946
- Surface Combustion Corp. v. CommissionerUnited States Tax Court · 1947
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