Legal Opinion

Riss & Co. v. Commissioner

United States Tax Court

Decided December 2, 1965No. Docket No. 74950Published

1. Held, the Tax Court has jurisdiction under sections 273(c) of the 1939 Code and 6861(c) of the 1954 Code to decide a question concerning interest on a deficiency, where the interest has been assessed in connection with the jeopardy assessment of the deficiency. 2. Held, further, section 6601(e) of the 1954 Code does not apply to taxes imposed by the 1939 Code, even though the net operating loss arises in a year governed by the 1954 Code. 3. Held, further, under the 1939…

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1. Held, the Tax Court has jurisdiction under sections 273(c) of the 1939 Code and 6861(c) of the 1954 Code to decide a question concerning interest on a deficiency, where the interest has been assessed in connection with the jeopardy assessment of the deficiency. 2. Held, further, section 6601(e) of the 1954 Code does not apply to taxes imposed by the 1939 Code, even though the net operating loss arises in a year governed by the 1954 Code. 3. Held, further, under the 1939 Code, interest on deficiencies eliminated by net operating loss carrybacks runs at least until the due dates of the…

1Opinion of the Court

Riss & Company, Inc. (a Delaware Corporation), Transferee, Petitioner, v. Commissioner of Internal Revenue, Respondent

Riss & Co. v. Commissioner

Docket No. 74950

United States Tax Court

45 T.C. 230; 1965 U.S. Tax Ct. LEXIS 9;

December 2, 1965, Filed

Decision will be entered in accordance with the computations submitted by respondent.

1. Held, the Tax Court has jurisdiction under sections 273(c) of the 1939 Code and 6861(c) of the 1954 Code to decide a question concerning interest on a deficiency, where the interest has been assessed in connection with the jeopardy assessment of the deficiency.

2.…

2Cases cited12 opinions

  1. Manning v. Seeley Tube & Box Co.Supreme Court of the United States · 1950
  2. Fuller v. CommissionerUnited States Tax Court · 1953
  3. Estate of Mary Redding Shedd, First National Bank of Arizona, Trustee v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1963
  4. COMMISSIONER OF INT. REVENUE v. Kilpatrick's EstateCourt of Appeals for the Sixth Circuit · 1944
  5. Shedd v. CommissionerUnited States Tax Court · 1961

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