Legal Opinion

Atlas Oil & Refining Corp. v. Commissioner

United States Tax Court

Decided October 31, 1951No. Docket Nos. 24764, 24765Published

Petitioner's books of account having been closed and balances carried forward at the end of each calendar year, held deficiencies determined on a fiscal year basis were incorrect, notwithstanding that petitioner reported its income for the years involved on the basis of a fiscal year ended November 30. Helvering v. Brooklyn City R. Co. (C. A. 2), 72 F. 2d 274, followed.

1Opinion of the Court

Atlas Oil and Refining Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Atlas Oil & Refining Corp. v. Commissioner

Docket Nos. 24764, 24765

United States Tax Court

17 T.C. 733; 1951 U.S. Tax Ct. LEXIS 47;

October 31, 1951, Promulgated

Decision will be entered for the petitioner.

Petitioner's books of account having been closed and balances carried forward at the end of each calendar year, held deficiencies determined on a fiscal year basis were incorrect, notwithstanding that petitioner reported its income for the years involved on the basis of a fiscal year ended November…

2Cases cited4 opinions

  1. Helvering v. Brooklyn City R. Co.Court of Appeals for the Second Circuit · 1934
  2. Kansas City Southern Ry. Co. v. Commissioner of Int. Rev.Court of Appeals for the Eighth Circuit · 1931
  3. Great West Printing Co. v. CommissionerCourt of Appeals for the Eighth Circuit · 1932
  4. Atlas Oil & Refining Corp. v. CommissionerUnited States Tax Court · 1951

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