Aycock v. Commissioner
United States Tax Court
Corporation organized April 1942 and dissolved 4 months later, having no actual business history for any 12-month period, held not entitled to use actual experience method prescribed in Internal Revenue Code, section 711 (a) (3) (B), for computing its excess profits tax.
1Opinion of the Court
OPINION.
Oppee, Judge:
Petitioners seek the advantage of computing the excess profits tax of their transferor, Crystal Products, Inc., under the provisions of section 711 (a) (3) (B),1 rather than under section 711 (a) (3) (A),1 the section used by respondent in computing the deficiency. They rest the claim to use the provisions of subsection (B) on the fact that Crystal Products had a short taxable year commencing in April 1942, the date of its organization, and ending on its dissolution four months later. Not only would this require the allowance of full yearly credits against a mere fraction…
Also in this document: Concurrence.
2Cases cited3 opinions
- Kamin Chevrolet Co. v. CommissionerUnited States Tax Court · 1944
- General Aniline & Film Corp. v. CommissionerUnited States Tax Court · 1944
- Pepsi Cola Co. v. CommissionerUnited States Tax Court · 1945
3Cited by1 opinion
- Aycock v. CommissionerUnited States Tax Court · 1948