Arrow-Hart & Hegeman Electric Co. v. Commissioner
United States Tax Court
1. On March 15, 1940, petitioner received from its Canadian subsidiary a dividend, the entire amount of which constituted "net abnormal income."
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1. On March 15, 1940, petitioner received from its Canadian subsidiary a dividend, the entire amount of which constituted "net abnormal income." Subsidiary's earnings and profits accumulated during period January 1 to March 15, 1940, were $ 10,350.94. Held, the amount of the dividend in excess of $ 10,350.94 represented net abnormal income attributable to prior taxable years excludible from gross income for excess profits tax purposes under the provisions of section 721 (c), I. R. C. 2. The amount of the chapter 1 tax deductible in computing petitioner's excess profits net income for 1940,…
1Opinion of the Court
HarlaN, Judge-.
The respondent determined deficiencies in income tax, declared value excess profits tax, and excess profits tax, as follows:
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In an amended petition filed at the trial, petitioner alleged an overpayment of excess profits tax in the amount of $7,032.14 for the calendar year 1940 as shown on claim for refund filed with the collector of internal revenue for the district of Connecticut on March 25, 1944. Also, in the amended petition petitioner alleges further overpayment of excess profits tax and interest for the calendar year 1940 and over-payments of income, declared…
2Cases cited3 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- Green Bay Lumber Co. v. CommissionerUnited States Tax Court · 1944
3Cited by54 opinions
- Harris Hardwood Co. v. CommissionerUnited States Tax Court · 1947
- E. B. & A. C. Whiting Co. v. CommissionerUnited States Tax Court · 1948
- James F. Waters, Inc. v. Commissioner of Internal Rev.Court of Appeals for the Ninth Circuit · 1947
- Mine & Smelter Supply Co. v. CommissionerUnited States Tax Court · 1948
- North Carolina Lumber Co. v. CommissionerUnited States Tax Court · 1952
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