Legal Opinion

Royal Frocks, Inc. v. Commissioner

United States Tax Court

Decided January 31, 1958No. Docket No. 41614PublishedCited by 1 opinion

Petitioner's timely claims for relief under section 722, I. R. C. 1939, for the years 1943 and 1944 made no claim for carryback of unused excess profits credit based on CABPNI from 1945. After the time prescribed by section 322 (b) (6), I. R. C. 1939, petitioner filed amended claims for such credit. Held, the amended claims are barred by the statute of limitations.

1Opinion of the Court

opinion.

FoReesteR, Judge:

The respondent has determined deficiencies in petitioner’s income tax and overassessments of its excess profits tax as follows:

Overassessment Deficiency income excess profits Year ended June SO tax tax

1943_ $10, 739. 82 $18, 270. 55

1944_____ 10,416.60 16,463.71

The events preceding such determinations were that the petitioner had filed timely claims for relief under section 722 of the Internal Revenue Code of 1939 for the taxable years noted above and the respondent had allowed in part the amounts so claimed by petitioner as its constructive average base period net…

2Cases cited2 opinions

  1. Headline Publications, Inc. v. CommissionerUnited States Tax Court · 1957
  2. Feature Publications, Inc. v. CommissionerUnited States Tax Court · 1957

3Cited by1 opinion

  1. Royal Frocks, Inc. v. CommissionerUnited States Tax Court · 1958

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