Williamson v. Commissioner
United States Tax Court
Petitioners filed their income tax returns for the short period from March 1, 1946, to December 31, 1946, in the process of changing from a fiscal year to a calendar year basis. Petitioners did not request or obtain the permission of the Commissioner to make the change, but the Commissioner accepted the returns and determined deficiencies based upon the short period. The record is silent concerning whether petitioners actually made changes in their accounting periods.
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Petitioners filed their income tax returns for the short period from March 1, 1946, to December 31, 1946, in the process of changing from a fiscal year to a calendar year basis. Petitioners did not request or obtain the permission of the Commissioner to make the change, but the Commissioner accepted the returns and determined deficiencies based upon the short period. The record is silent concerning whether petitioners actually made changes in their accounting periods. The Commissioner based his deficiencies upon a computation of the tax in accordance with the provisions of section 47 (c) (1),…
1Opinion of the Court
OPINION.
BRUCE, Judge: Eespondent determined deficiencies in petitioners’ income taxes for the short period from March 1, 1946, to December 31,1946, in accordance with the provisions of section 47 (c) (1) of the Internal Eevenue Code. Petitioners contend that these determinations are erroneous. They argue (1) that since the permission of the Commissioner to change accounting periods was not obtained, the period March 1 until the end of February remained the petitioners’ correct taxable year and respondent cannot determine a deficiency for an unauthorized period, and (2) that, if the short…
2Cases cited6 opinions
- Helvering v. Brooklyn City R. Co.Court of Appeals for the Second Circuit · 1934
- Visintainer v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1951
- Linen Thread Co. v. CommissionerUnited States Tax Court · 1950
- Visintainer v. CommissionerUnited States Tax Court · 1949
- Bass v. StimsonUnited States Tax Court · 1953
1 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Williamson v. CommissionerUnited States Tax Court · 1954