Crossett Western Co. v. Commissioner
United States Tax Court
1. Held, section 718 (b) (3), Internal Revenue Code, being clear and unambiguous, does not justify resort to Congressional reports for interpretation. 2. Held, further, application of the section requiring the deduction of the amount of earnings and profits of another corporation which previously at any time were included in the accumulated earnings and profits of a corporation by reason of a tax-free reorganization is mandatory, irrespective of the fact that because of…
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1. Held, section 718 (b) (3), Internal Revenue Code, being clear and unambiguous, does not justify resort to Congressional reports for interpretation. 2. Held, further, application of the section requiring the deduction of the amount of earnings and profits of another corporation which previously at any time were included in the accumulated earnings and profits of a corporation by reason of a tax-free reorganization is mandatory, irrespective of the fact that because of operating losses in the intervening years taxpayer had no accumulated earnings and profits at the beginning of the taxable…
1Opinion of the Court
Crossett Western Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Crossett Western Co. v. Commissioner
Docket No. 3054
United States Tax Court
4 T.C. 783; 1945 U.S. Tax Ct. LEXIS 229;
February 13, 1945, Promulgated
Decision will be entered under Rule 50.
1. Held, section 718 (b) (3), Internal Revenue Code, being clear and unambiguous, does not justify resort to Congressional reports for interpretation.
2. Held, further, application of the section requiring the deduction of the amount of earnings and profits of another corporation which previously at any time were included in the…
Also in this document: Concurrence.
2Cases cited1 opinion
- Crossett Western Co. v. CommissionerUnited States Tax Court · 1945