Bell Fibre Products Corp. v. Commissioner
United States Tax Court
Effective Jan. 1, 1969, petitioner elected, in accordance with sec. 1372, I.R.C. 1954, to become an electing small business corporation. In prior taxable years, petitioner had made qualified investments, entitling it to investment credits against tax under sec. 38, I.R.C. 1954, and related provisions.
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Effective Jan. 1, 1969, petitioner elected, in accordance with sec. 1372, I.R.C. 1954, to become an electing small business corporation. In prior taxable years, petitioner had made qualified investments, entitling it to investment credits against tax under sec. 38, I.R.C. 1954, and related provisions. At the time of the election, petitioner and its shareholders were not aware that the election would subject petitioner to liability for an investment credit recapture tax for the taxable period ended Dec. 31, 1968, unless they filed an assumption agreement pursuant to sec. 1.47-4(b), Income Tax…
1Opinion of the Court
Bell Fibre Products Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Bell Fibre Products Corp. v. Commissioner
Docket No. 9314-72
United States Tax Court
65 T.C. 753; 1976 U.S. Tax Ct. LEXIS 177;
January 19, 1976, Filed
Decision will be entered under Rule 155.
Effective Jan. 1, 1969, petitioner elected, in accordance with sec. 1372, I.R.C. 1954, to become an electing small business corporation. In prior taxable years, petitioner had made qualified investments, entitling it to investment credits against tax under sec. 38, I.R.C. 1954, and related provisions. At the time of the…
2Cases cited17 opinions
- United States v. IoziaDistrict Court, S.D. New York · 1952
- Sperapani v. CommissionerUnited States Tax Court · 1964
- Barclay White Co. v. Unemployment Compensation Board of ReviewSupreme Court of Pennsylvania · 1946
- Cary v. CommissionerUnited States Tax Court · 1963
- Columbia Iron & Metal Co. v. CommissionerUnited States Tax Court · 1973
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