Legal Opinion

Jefferson Amusement Co. v. Commissioner

United States Tax Court

Decided April 9, 1952No. Docket No. 27267PublishedCited by 28 opinions

Petitioner seeks general relief under the provisions of section 722 of the Code from excess profits taxes for the years 1942, 1943, 1944, and 1945. Since incorporation it has been engaged in the business of operating a chain of motion picture theatres in the State of Texas.

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Petitioner seeks general relief under the provisions of section 722 of the Code from excess profits taxes for the years 1942, 1943, 1944, and 1945. Since incorporation it has been engaged in the business of operating a chain of motion picture theatres in the State of Texas. Held: 1. During the years 1936 and 1937, petitioner established additional theatres which constituted a change in the character of its business, section 722 (b) (4), and relief therefor has been determined. 2. During 1938, petitioner remodeled and increased the seating capacity of a theatre. Petitioner failed to meet the…

1Opinion of the Court

OPINION.

Black, Judge:

Petitioner seeks relief as provided by section 722 of the Internal Revenue Code in regard to its excess profits tax liability for the years 1942, 1943, 1944, and 1945. Petitioner also seeks additional relief under the provisions of section 722 of the Code by reason of a constructive unused excess profits credit carry-over from 1940 and 1941 to 1942.

Petitioner contends it qualifies for relief under section 722 (b) (4) by reason of the following facts: (1) that it acquired during the base period years additional theatres; (2) that it remodeled and increased the seating…

2Cases cited6 opinions

  1. Wisconsin Farmer Co. v. CommissionerUnited States Tax Court · 1950
  2. Avey Drilling Machine Co. v. CommissionerUnited States Tax Court · 1951
  3. Toledo Stove & Range Co. v. CommissionerUnited States Tax Court · 1951
  4. Victory Glass, Inc. v. CommissionerUnited States Tax Court · 1951
  5. Ray Campbell, Wise & Wright, Inc. v. CommissionerUnited States Tax Court · 1950

1 more not listed; retrieve them via the Exa API.

3Cited by28 opinions

  1. Packer Pub. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1954
  2. Neilsen Lithographing Co. v. CommissionerUnited States Tax Court · 1952
  3. Brown Paper Mill Co. v. CommissionerUnited States Tax Court · 1954
  4. Pelton & Crane Co. v. CommissionerUnited States Tax Court · 1953
  5. Crowell-Collier Pub. Co. v. CommissionerUnited States Tax Court · 1956

23 more not listed; retrieve them via the Exa API.

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