Legal Opinion
Phoenix Coal Company, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided March 13, 1956No. 182, Docket 23751PublishedCited by 49 opinions
1Opinion of the Court
CLARK, Chief Judge.
The petitioning taxpayer here seeks review of the action of the Tax Court in sustaining the Commissioner’s assessment of deficiencies in its income tax for the years 1946 and 1948. Two questions are presented. The first arises because the Commissioner, in making adjustments of petitioner’s 1946 income tax return, considered items on its 1945 return, adjustment of which was barred by the statute of limitations.
Petitioner reported income and paid a tax thereon in 1945. It did likewise in 1946. In 1947 and 1948, it reported a net operating loss. As provided in § 122(b) of the…
2Cases cited14 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Boehm v. CommissionerSupreme Court of the United States · 1945
- Commissioner v. Scottish American Investment Co.Supreme Court of the United States · 1945
- Raytheon Production Corp. v. Commissioner of Int. Rev.Court of Appeals for the First Circuit · 1944
- Durkee v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1947
9 more not listed; retrieve them via the Exa API.
3Cited by49 opinions
- Mennuto v. CommissionerUnited States Tax Court · 1971
- Calumet Industries, Inc. v. CommissionerUnited States Tax Court · 1990
- Bresler v. CommissionerUnited States Tax Court · 1975
- Hill v. CommissionerUnited States Tax Court · 1990
- Harris v. CommissionerUnited States Tax Court · 1992
44 more not listed; retrieve them via the Exa API.