Legal Opinion

Kurtzon v. Commissioner

United States Tax Court

Decided March 21, 1952No. Docket No. 29746Published

1. A partnership had to refund excessive profits under the Renegotiation Law. Petitioner, a partner, included in his 1945 income a part of his share of these excessive profits. Held, petitioner is entitled to a tax credit under section 3806. 2. Because of a net operating loss deduction from a loss incurred in 1947, petitioner had received refunds of all 1945 income taxes before the renegotiation tax credits were applied.

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1. A partnership had to refund excessive profits under the Renegotiation Law. Petitioner, a partner, included in his 1945 income a part of his share of these excessive profits. Held, petitioner is entitled to a tax credit under section 3806. 2. Because of a net operating loss deduction from a loss incurred in 1947, petitioner had received refunds of all 1945 income taxes before the renegotiation tax credits were applied. The Commissioner has determined a deficiency which petitioner alleges is contrary to the definition of deficiency contained in section 271 of the Internal Revenue Code. Held,…

1Opinion of the Court

Morris Kurtzon, Petitioner, v. Commissioner of Internal Revenue, Respondent

Kurtzon v. Commissioner

Docket No. 29746

United States Tax Court

17 T.C. 1542; 1952 U.S. Tax Ct. LEXIS 238;

March 21, 1952, Promulgated

Decision will be entered that there is a deficiency of $ 5,007.60.

1. A partnership had to refund excessive profits under the Renegotiation Law. Petitioner, a partner, included in his 1945 income a part of his share of these excessive profits. Held, petitioner is entitled to a tax credit under section 3806.

2. Because of a net operating loss deduction from a loss incurred in 1947, petitioner…

Also in this document: Dissent.

2Cases cited4 opinions

  1. Kurtzon v. CommissionerUnited States Tax Court · 1952
  2. Stow Mfg. Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1951
  3. Baltimore Foundry & Machine Corp. v. CommissionerUnited States Tax Court · 1946
  4. United States v. SarkozyDistrict Court, E.D. Michigan · 1951

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