General Aniline & Film Corp. v. Commissioner
United States Tax Court
A corporation which had reported its income on a calendar year basis was dissolved by merger on September 30, 1940. Held, that the corporation's taxable year was a period of less than 12 months and that the Commissioner did not err in placing its excess profits tax net income for such taxable year on an annual basis, under the provisions of section 711 (a) (3) of the Internal Revenue Code.
1Opinion of the Court
OPINION.
Disney, Judge-.
This case involves excess profits tax. Deficiency was determined in the amount of $6,471.11. The question presented is whether the Commissioner erred in placing upon an annual basis, under section 711 (a) (3) of the Internal Revenue Code,1 the excess profits net income of petitioner’s subsidiary, Ozalid Corporation (hereinafter sometimes referred to as.Ozalid), for the period of its existence in 1940, from January 1 to September 30.
All facts were stipulated. Omitting formal parts, the stipulation reads as follows:
1. General Aniline & Film Corporation is a Delaware…
2Cases cited3 opinions
- Bankers' Trust Co. v. BowersCourt of Appeals for the Second Circuit · 1923
- Journal Publishing Co. v. CommissionerUnited States Tax Court · 1944
- Royal Highlanders v. CommissionerUnited States Tax Court · 1942
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- Camp Wolters Land Co. v. CommissionerUnited States Tax Court · 1945
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