Ellis Corp. v. Commissioner
United States Tax Court
Held, in computing the adjustment under sec. 545(b)(5) on account of the excess of net long-term capital gains over short-term capital losses, any tax attributable to such capital gains must be taken into account regardless of when it may have accrued.
1Opinion of the Court
Quealy, Judge:
Respondent determined deficiencies against the petitioner for additional taxes for the taxable years 1961 to 1966, inclusive, in the following amounts:
Taxable year Deficiency
1961_ $731. 44
1962 _ 4,858.19
1963 _ 4,254.18
Taxable year Deficiency
1964-$3, 534. 00
1965 - 1,491.50
1966 - 2,553. 61
An agreement has been entered into by the parties disposing of all issues presented thereby, except for the resulting computation of the personal holding company tax imposed by section 541 for the taxable years 1962 to 1966, inclusive.
FINDINGS OF FACT
The stipulation of facts and exhibits attached…
2Cases cited2 opinions
- Hart Metal Products Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1971
- Litchfield Securities Corporation v. United StatesCourt of Appeals for the Second Circuit · 1963
3Cited by10 opinions
- Kluger Associates, Inc. v. CommissionerUnited States Tax Court · 1978
- Kluger Associates, Inc. v. CommissionerCourt of Appeals for the Second Circuit · 1980
- Broadview Lumber Co. v. United StatesCourt of Appeals for the Seventh Circuit · 1977
- Metro Leasing & Dev. Corp. v. Comm'rUnited States Tax Court · 2002
- Broadview Lumber Co., Inc., Plaintiff-Appellant-Cross-Appellee v. United States of America, Defendant-Appellee-Cross-Appellant. Broadview Lumber Co., Inc., Successor-In-Interest by Statutory Merger to Allen County Lumber Co., Inc., Plaintiff-Appellant-Cross-Appellee v. United States of America, Defendant-Appellee-Cross-AppellantCourt of Appeals for the Seventh Circuit · 1977
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