Legal Opinion

Ambassador Hotel Co. v. Commissioner

United States Tax Court

Decided October 29, 1954No. Docket No. 33123Published

1. Excess Profits Tax Income -- Exclusion -- Profit on Purchase of Own Bonds -- Sec. 711 (a) (2) (E). -- Profits made by the petitioner on the purchase of its own bonds during the taxable year were excluded from excess profits net income under the provisions of section 711 (a) (2) (E). 2. Consents -- Corporate Seal -- Sec. 22 (b) (9). -- A consent under section 22 (b) (9) is not invalid because of the absence of the corporate seal, particularly where the consent was bound as…

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1. Excess Profits Tax Income -- Exclusion -- Profit on Purchase of Own Bonds -- Sec. 711 (a) (2) (E). -- Profits made by the petitioner on the purchase of its own bonds during the taxable year were excluded from excess profits net income under the provisions of section 711 (a) (2) (E). 2. Consents -- Corporate Seal -- Sec. 22 (b) (9). -- A consent under section 22 (b) (9) is not invalid because of the absence of the corporate seal, particularly where the consent was bound as a part of the return to which the seal was affixed, although the instructions on the back of the consent were that such…

1Opinion of the Court

Ambassador Hotel Company of Los Angeles, Petitioner, v. Commissioner of Internal Revenue, Respondent

Ambassador Hotel Co. v. Commissioner

Docket No. 33123

United States Tax Court

23 T.C. 163; 1954 U.S. Tax Ct. LEXIS 51;

October 29, 1954, Filed

Decision will be entered under Rule 50.

1. Excess Profits Tax Income -- Exclusion -- Profit on Purchase of Own Bonds -- Sec. 711 (a) (2) (E). -- Profits made by the petitioner on the purchase of its own bonds during the taxable year were excluded from excess profits net income under the provisions of section 711 (a) (2) (E).

2. Consents -- Corporate Seal --…

2Cases cited9 opinions

  1. Helvering v. Metropolitan Edison Co.Supreme Court of the United States · 1939
  2. New York Cent. R. Co. v. Commissioner of Internal Rev.Court of Appeals for the Second Circuit · 1935
  3. Athens Roller Mills v. Com'r of Internal RevenueCourt of Appeals for the Sixth Circuit · 1943
  4. American Gas & Elec. Co. v. Commissioner of Internal Rev.Court of Appeals for the Second Circuit · 1936
  5. Pictorial Printing Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1930

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