Legal Opinion

Premier Products Co. v. Commissioner

United States Tax Court

Decided July 21, 1943No. Docket Nos. 110690, 110691PublishedCited by 32 opinions

Excess Profits Tax Under Subchapter E of Internal Revenue Code. -- Several years prior to the taxable year 1940 the taxpayer corporation acquired policies of insurance on the life of its principal stockholder. During the taxable year the stockholder died and the proceeds of the policies were paid to the taxpayer corporation.

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Excess Profits Tax Under Subchapter E of Internal Revenue Code. -- Several years prior to the taxable year 1940 the taxpayer corporation acquired policies of insurance on the life of its principal stockholder. During the taxable year the stockholder died and the proceeds of the policies were paid to the taxpayer corporation. Held, the net proceeds thus received (after deducting from the gross proceeds the taxpayer's investment in the policies and the portion of the income and defense taxes applicable to such gross proceeds less the investment) constituted "abnormal income" as that term is…

1Opinion of the Court

OPINION.

Black, Judge:

The question involved in these proceedings arises in connection with the excess profits tax imposed by subchapter E of chapter 2 (sections 710 to 752, inclusive) of the Internal Revenue Code, which subchapter may be cited as the “Excess Profits Tax Act of 1940” and was inserted in the Code by Title II, section 201, of the Second Revenue Act of 1940. It has since been amended by the Excess Profits Tax Amendments of 1941, approved March 7, 1941; by Title II of the Revenue Act of 1941, approved September 20, 1941; and by Title II of the Revenue Act of 1942. These taxes are…

Also in this document: Concurrence.

2Cited by32 opinions

  1. Green Bay Lumber Co. v. CommissionerUnited States Tax Court · 1944
  2. W. B. Davis & Son, Inc. v. CommissionerUnited States Tax Court · 1945
  3. W. B. Knight Machinery Co. v. CommissionerUnited States Tax Court · 1946
  4. Harris Hardwood Co. v. CommissionerUnited States Tax Court · 1947
  5. E. T. Slider, Inc. v. CommissionerUnited States Tax Court · 1945

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