Pepsi Cola Co. v. Commissioner
United States Tax Court
1. A corporation which had reported its income on a calendar year basis was dissolved by merger on June 30, 1941. Held, that the period from January 1 to June 30, 1941, constitutes a short taxable year and the excess profits net income must be placed on an annual basis under section 711 (a) (3) of the Internal Revenue Code. 2. In his notice of deficiency the Commissioner determined that the petitioner's excess profits net income for the period July 1 to December 31, 1940,…
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1. A corporation which had reported its income on a calendar year basis was dissolved by merger on June 30, 1941. Held, that the period from January 1 to June 30, 1941, constitutes a short taxable year and the excess profits net income must be placed on an annual basis under section 711 (a) (3) of the Internal Revenue Code. 2. In his notice of deficiency the Commissioner determined that the petitioner's excess profits net income for the period July 1 to December 31, 1940, was equal to one-half of its excess profits net income for the calendar year 1940, for purposes of the 12-month period…
1Opinion of the Court
Pepsi Cola Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Pepsi Cola Co. v. Commissioner
Docket No. 3458
United States Tax Court
5 T.C. 190; 1945 U.S. Tax Ct. LEXIS 150;
June 6, 1945, Promulgated
An excess profits tax deficiency in the amount of $ 1,449,899.93, which is the amount determined by the respondent in his deficiency notice, is here redetermined.
1. A corporation which had reported its income on a calendar year basis was dissolved by merger on June 30, 1941. Held, that the period from January 1 to June 30, 1941, constitutes a short taxable year and the excess profits…
2Cases cited8 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Helvering v. Midland Mutual Life InsuranceSupreme Court of the United States · 1937
- William Leveen Corp. v. CommissionerUnited States Tax Court · 1944
- Kamin Chevrolet Co. v. CommissionerUnited States Tax Court · 1944
- First Nat'l Bank v. CommissionerUnited States Tax Court · 1942
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