Guest v. Commissioner
United States Tax Court
In computing 90 per cent victory tax limitation on taxes "imposed by" chapter 1 under Internal Revenue Code, section 456, held addition to 1943 tax liability of 25 per cent of 1942 tax is not affected as being "imposed by" section 6 of Current Tax Payment Act and not by chapter 1.
1Opinion of the Court
OPINION.
Opper, Judge-.
Respondent determined a deficiency in income and victory tax liability for the year 1943 in the amount of $18,883.17.
The sole litigated question is whether in computing the victory tax limitation in section 456 of the Internal Revenue Code, chapter 1 tax for 1943 includes the increase in tax for that year occasioned by section 6 (a) of the Current Tax Payment Act of 1943.
All of the facts have been incorporated in a stipulation of facts which are hereby found accordingly, as follows:
1. The petitioner is an individual who resides in Palm Beach, Florida. The petitioner’s…
2Cases cited3 opinions
- Fleming v. Mohawk Wrecking & Lumber Co.Supreme Court of the United States · 1947
- Carpenter v. CommissionerUnited States Tax Court · 1948
- Knox v. CommissionerUnited States Tax Court · 1948
3Cited by9 opinions
- Marx v. CommissionerUnited States Tax Court · 1949
- Gagne v. CommissionerUnited States Tax Court · 1951
- United States v. TourtellotDistrict Court, M.D. North Carolina · 2012
- McKenna v. GrangerDistrict Court, W.D. Pennsylvania · 1953
- Gagne v. CommissionerUnited States Tax Court · 1951
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