Legal Opinion

Royal Frocks, Inc. v. Commissioner

United States Tax Court

Decided January 31, 1958No. Docket No. 41614Published

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

Royal Frocks, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Royal Frocks, Inc. v. Commissioner

Docket No. 41614

United States Tax Court

29 T.C. 796; 1958 U.S. Tax Ct. LEXIS 266;

January 31, 1958, Filed

Decision will be entered under Rule 50.

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…

2Cases cited3 opinions

  1. Headline Publications, Inc. v. CommissionerUnited States Tax Court · 1957
  2. Feature Publications, Inc. v. CommissionerUnited States Tax Court · 1957
  3. Royal Frocks, Inc. v. CommissionerUnited States Tax Court · 1958

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