Schick v. Commissioner
United States Tax Court
Respondent determined a deficiency in the income tax of the transferor for its "taxable year ended January 31, 1959." The transferor's proper "taxable year" was the fiscal year ended October 31, 1959. Held, there is no deficiency for the period November 1, 1958, to January 31, 1959, and we have no jurisdiction over any other period.
1Opinion of the Court
Forrester, Judge:
Respondent bas determined that petitioners are liable as transferees for a deficiency in tbe income tax of Schick Enterprises, Inc., for its “taxable year ended January 31, 1959,” in the amount of $7,360.14 and an additional deficiency in the amount of $215.70. Petitioners concede transferee liability but contend that there is no deficiency in the tax of the transferor. The issues are (1) whether the deficiency determined in the tax of the transferor was for a proper taxable period; (2) whether, under section 337,2 the gain realized by the transferor upon the sale of a…
2Cases cited10 opinions
- C. D. Spangler and Veva C. Spangler v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
- Gensinger v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1953
- Estate of Scofield v. CommissionerUnited States Tax Court · 1956
- Spangler v. CommissionerUnited States Tax Court · 1959
- United States v. KingmanCourt of Appeals for the Fifth Circuit · 1948
5 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Sanderling, Inc. v. CommissionerUnited States Tax Court · 1976
- Atlas Tool Co. v. CommissionerUnited States Tax Court · 1978
- Burford v. CommissionerUnited States Tax Court · 1981
- Century Data Systems, Inc. v. CommissionerUnited States Tax Court · 1983
- Pittsburgh Realty Inv. Trust v. CommissionerUnited States Tax Court · 1976
6 more not listed; retrieve them via the Exa API.