John Wanamaker Philadelphia v. Commissioner
United States Board of Tax Appeals
1. Where the Commissioner determines an overassessment of taxes, which determination is due to the partial rejection of a claim in abatement, the Board has jurisdiction. 2. The Board has jurisdiction to determine the correct tax liability on all income for a fiscal year ending January 31, 1916. 3. The Commissioner's disallowance of certain reductions in inventory values made for the purpose of reducing the inventories to the basis of cost or market, whichever was lower, is…
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1. Where the Commissioner determines an overassessment of taxes, which determination is due to the partial rejection of a claim in abatement, the Board has jurisdiction. 2. The Board has jurisdiction to determine the correct tax liability on all income for a fiscal year ending January 31, 1916. 3. The Commissioner's disallowance of certain reductions in inventory values made for the purpose of reducing the inventories to the basis of cost or market, whichever was lower, is approved because the amounts of the reductions have not been shown to have been correct although the method under which…
1Opinion of the Court
*497OPINION.
Murdock:
The Commissioner’s final determination of an overas-sessment of taxes against John Wanamaker Philadelphia for the fiscal year ended January 31,1917, resulted from a rejection in part of a claim in abatement; therefore we have jurisdiction as to that fiscal year. Continental Accounting & Audit Co., 2 B. T. A. 761; Powell Coal Co., 12 B. T. A. 492.
The Commissioner challenges our jurisdiction to consider., and determine the question of a deficiency for the period from February 1,1915, to December 31, 1915, both dates inclusive, which period was a part of the fiscal year ended…
2Cases cited7 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Fawcus MacHine Co. v. United StatesSupreme Court of the United States · 1931
- Wickwire v. ReineckeSupreme Court of the United States · 1927
- Lucas v. Kansas City Structural Steel Co.Supreme Court of the United States · 1930
- Reinecke v. SpaldingSupreme Court of the United States · 1930
2 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- John Wanamaker Philadelphia, Inc. v. The United States. John Wanamaker Philadelphia, Inc. (Successor by Merger to John Wanamaker New York, Inc.) v. The United StatesUnited States Court of Claims · 1966
- John Wanamaker Philadlephia, Inc. v. United StatesUnited States Court of Claims · 1966
- Estate of Cohn v. CommissionerUnited States Tax Court · 1974
- Carmichael Tile Co. v. CommissionerUnited States Tax Court · 1950
- Estate of Cohn v. CommissionerUnited States Tax Court · 1974
2 more not listed; retrieve them via the Exa API.