Epoch Food Service, Inc. v. Commissioner
United States Tax Court
Held, petitioner's 1973 franchise tax deduction determined within the guidelines of sec. 461(d), I.R.C. 1954.
1Opinion of the Court
Wiles, Judge:
Respondent determined a $2,303 deficiency in petitioner’s 1973 Federal income tax. The sole issue is the extent of petitioner’s 1973 California State franchise deduction.
FINDINGS OF FACT
All of the facts were stipulated and are found accordingly.
Epoch Food Service, Inc. (hereinafter petitioner), an accrual method, calendar year taxpayer, had its principal office in Palo Alto, Calif., when it timely filed its 1973 return with the Internal Revenue Service Center at Fresno, Calif., and when it filed its petition in this case.
Petitioner was incorporated in California on April 13,…
2Cases cited4 opinions
- Grace Bros. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1949
- Gorman Lumber Sales Co. v. CommissionerUnited States Tax Court · 1949
- Central Inv. Corp. v. CommissionerUnited States Tax Court · 1947
- Grace Bros., Inc. v. CommissionerUnited States Tax Court · 1948
3Cited by11 opinions
- Charles Schwab Corp. v. CommissionerUnited States Tax Court · 1996
- Charles Schwab Corp. v. Comm'rUnited States Tax Court · 2004
- Charles Schwab Corp. v. CommissionerCourt of Appeals for the Ninth Circuit · 2007
- Globe Newspaper Co. v. United StatesUnited States Court of Claims · 1980
- Charles Schwab Corp. v. Comm'rUnited States Tax Court · 2004
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