Legal Opinion

Ambassador Hotel Co. v. Commissioner

United States Tax Court

Decided April 24, 1959No. Docket No. 61486Published

The Commissioner determined a deficiency in petitioner's income tax for the year 1944, which resulted by operation of law from the adjustment of said corporation's excess profits tax for the same taxable year, in accordance with a prior decision of this Court. The petitioner pleaded in defense, only the general statute of limitation under section 275 of the 1939 Code.

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The Commissioner determined a deficiency in petitioner's income tax for the year 1944, which resulted by operation of law from the adjustment of said corporation's excess profits tax for the same taxable year, in accordance with a prior decision of this Court. The petitioner pleaded in defense, only the general statute of limitation under section 275 of the 1939 Code. Held: 1. That assessment of the deficiency is not prevented or barred, because of the applicability of section 3807 of the 1939 Code (relating to period of limitation in case of related taxes under chapter 1 and chapter 2 of…

1Opinion of the Court

Ambassador Hotel Company of Los Angeles, Petitioner, v. Commissioner of Internal Revenue, Respondent

Ambassador Hotel Co. v. Commissioner

Docket No. 61486

United States Tax Court

32 T.C. 208; 1959 U.S. Tax Ct. LEXIS 187;

April 24, 1959, Filed

Decision will be entered for the respondent.

The Commissioner determined a deficiency in petitioner's income tax for the year 1944, which resulted by operation of law from the adjustment of said corporation's excess profits tax for the same taxable year, in accordance with a prior decision of this Court. The petitioner pleaded in defense, only the general…

2Cases cited10 opinions

  1. Freuler v. HelveringSupreme Court of the United States · 1934
  2. Freshman v. AtkinsSupreme Court of the United States · 1925
  3. Booth v. FletcherCourt of Appeals for the D.C. Circuit · 1938
  4. Latta v. Western Inv. Co.Court of Appeals for the Ninth Circuit · 1949
  5. Commissioner of Internal Revenue v. Michael Shapiro and Rae ShapiroCourt of Appeals for the Seventh Circuit · 1960

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