State Farming Co. v. Commissioner
United States Tax Court
S Corporation paid a sum to California in settlement of an action under a California statute which prohibited corporations with shareholders of certain types of alien descent from owning land in California. S Corporation was wholly owned by two individual United States citizens of one such descent. Eight years later, California granted refunds for the payments and a check was issued which listed S Corporation and the two individual shareholders as payees.
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S Corporation paid a sum to California in settlement of an action under a California statute which prohibited corporations with shareholders of certain types of alien descent from owning land in California. S Corporation was wholly owned by two individual United States citizens of one such descent. Eight years later, California granted refunds for the payments and a check was issued which listed S Corporation and the two individual shareholders as payees. The shareholders deposited the warrant in a special account of their own. No part of the refund was ever reported as taxable income by S…
1Opinion of the Court
OPINION
FoeResteR, Judge:
Respondent has determined the following deficiencies in income tas:
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Certain adjustments have been agreed to and the remaining issues for our determination are as follows:(1) Whether the Commissioner may disallow certain net operating loss deductions by adjusting income in years prior to those covered in the statutory notices of deficiency when the relevant prior years are barred for deficiency purposes by the statute of limitations.(2) Whether any part of a payment of $127,969.86 received in 1952 from the State of California constitutes taxable income to…
2Cases cited15 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Neirbo Co. v. Bethlehem Shipbuilding Corp.Supreme Court of the United States · 1939
- Bogardus v. CommissionerSupreme Court of the United States · 1937
- Oyama v. CaliforniaSupreme Court of the United States · 1947
- Helvering v. PriceSupreme Court of the United States · 1940
10 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Mennuto v. CommissionerUnited States Tax Court · 1971
- Cluck v. CommissionerUnited States Tax Court · 1995
- Calumet Industries, Inc. v. CommissionerUnited States Tax Court · 1990
- Hill v. CommissionerUnited States Tax Court · 1990
- Harris v. CommissionerUnited States Tax Court · 1992
19 more not listed; retrieve them via the Exa API.