Miles Production Co. v. Commissioner
United States Tax Court
The Commissioner determined deficiencies in petitioner's windfall profit tax for calendar years 1981 and 1982. Petitioner filed Federal income tax returns for the taxable years ended June 30, 1981, June 30, 1982, and June 30, 1983. It did not file annual windfall profit tax returns.
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The Commissioner determined deficiencies in petitioner's windfall profit tax for calendar years 1981 and 1982. Petitioner filed Federal income tax returns for the taxable years ended June 30, 1981, June 30, 1982, and June 30, 1983. It did not file annual windfall profit tax returns. Petitioner claimed overpayments of windfall profit tax as credits against its income tax liabilities on its income tax returns, amended income tax return, and claims for refund based upon application of the net income limitation. Petitioner and the Commissioner executed Special Consents to Extend the Time to…
1Opinion of the Court
OPINION
GOFFE, Judge:
The Commissioner determined deficiencies in petitioner’s windfall profit tax under section 4986,1 for the calendar years 1981 and 1982 and additions to tax for those years as follows:
Additions to tax
Calendar year Deficiency in tax Sec. 6653(a)(1) Sec. 6653(a)(2)
1981 $133,235.88 $6,661.79 *
1982 78,411.80 3,920.59 *
*50 percent of the interest due on $133,235.88 for the calendar year 1981 and on $78,411.80 for the calendar year 1982.
The issue to be decided is whether a statutory notice of deficiency for windfall profit tax based upon a calendar year is valid when petitioner…
2Cases cited11 opinions
- Woods v. CommissionerUnited States Tax Court · 1989
- Sanderling, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1978
- Sanderling, Inc. v. CommissionerUnited States Tax Court · 1976
- Page v. CommissionerUnited States Tax Court · 1986
- Transco Exploration Co. v. CommissionerUnited States Tax Court · 1990
6 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Dees v. Comm'rUnited States Tax Court · 2017
- Miles Production Co. v. CommissionerUnited States Tax Court · 1991