Legal Opinion

Doug-Long, Inc. v. Commissioner

United States Tax Court

Decided October 11, 1979No. Docket No. 11051-76Published

Prior to issuing the statutory notice, respondent notified petitioner of proposed deficiencies in its income tax and accumulated earnings tax for 1974. Petitioner protested a portion of the income tax deficiency and the entire accumulated earnings tax deficiency to the District Director.

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Prior to issuing the statutory notice, respondent notified petitioner of proposed deficiencies in its income tax and accumulated earnings tax for 1974. Petitioner protested a portion of the income tax deficiency and the entire accumulated earnings tax deficiency to the District Director. Petitioner subsequently conceded the entire income tax deficiency, and in a prior opinion (72 T.C. 158), we held that petitioner was liable for accumulated earnings tax for 1974. Held: In calculating petitioner's "accumulated taxable income" for 1974, the portion of the income tax deficiency which was…

1Opinion of the Court

Doug-Long, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Doug-Long, Inc. v. Commissioner

Docket No. 11051-76

United States Tax Court

73 T.C. 71; 1979 U.S. Tax Ct. LEXIS 41;

October 11, 1979, Filed

Prior to issuing the statutory notice, respondent notified petitioner of proposed deficiencies in its income tax and accumulated earnings tax for 1974. Petitioner protested a portion of the income tax deficiency and the entire accumulated earnings tax deficiency to the District Director. Petitioner subsequently conceded the entire income tax deficiency, and in a prior opinion (72 T.C.…

2Cases cited12 opinions

  1. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  2. United States v. CorrellSupreme Court of the United States · 1967
  3. Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
  4. National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
  5. Great Island Holding Corp. v. CommissionerUnited States Tax Court · 1945

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