Hardaway Motor Co. v. Commissioner
United States Tax Court
Petitioner deferred payment of a portion of its excess profits taxes for 1944 and 1945 in accordance with section 710 (a) (5), I. R. C., pending consideration of applications for relief under section 722. It subsequently executed an agreement in which it conceded that its constructive average base period net income for those years was "none."
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Petitioner deferred payment of a portion of its excess profits taxes for 1944 and 1945 in accordance with section 710 (a) (5), I. R. C., pending consideration of applications for relief under section 722. It subsequently executed an agreement in which it conceded that its constructive average base period net income for those years was "none." On November 2, 1948, the Executive Committee of the Excess Profits Tax Council took action approving a determination of a panel of the Excess Profits Tax Council which had approved a proposed constructive average base period net income of certain amounts…
1Opinion of the Court
FINDINGS OF FACT AND OPINION.
Raum, Judge:
In a notice of deficiency dated August 21, 1950, the Commissioner asserted deficiencies in excess profits tax for the years 1944 and 1945 in the amounts of $15,446.36 and $14,904.68, respectively. These deficiencies are based exclusively upon that portion of petitioner’s excess profits taxes for 1944 and 1945 the payment of which it had elected to defer under section 710 (a) (5) of the Internal Revenue Code,1 pending the consideration of its claims to relief under section 722. Cf. Tribune Publishing Co., 17 T. C. 1228, 1236-1237. Petitioner has…
2Cited by9 opinions
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- Commissioner of Internal Revenue v. The S. Frieder & Sons Company, the S. Frieder & Sons Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1957
- Hardaway Motor Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
- Calvert Iron Works, Inc. v. CommissionerUnited States Tax Court · 1956
- American Enka Corp. v. CommissionerUnited States Tax Court · 1958
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