Will County Title Co. v. Commissioner
United States Board of Tax Appeals
JURISDICTION. - The Commissioner determined a deficiency in income tax for 1934 and an overassessment of excess profits tax greater than the amount of the deficiency in income tax, thus making a net overassessment of the two taxes. Held, that a petition for redetermination is within our jurisdiction in so far as it pertains to the deficiency in income tax, but not as to the overassessment of excess profits tax.
1Opinion of the Court
OPINION.
Arundell:
The petition in this case is based on determinations of the Commissioner as follows:
1933, income tax overassessment_$57.92
1934, income tax deficiency_ 529.25
1934, excess profits tax overassessment_ 745.04
The parties have stipulated that for the year 1933 the Board may enter an order dismissing the proceeding for lack of jurisdiction. For the year 1934 the parties have stipulated to submit the question of jurisdiction for determination.
As set out above, the respondent has determined a deficiency in income tax in the amount of $529.25 and an overassessment of excess profits tax…
2Cited by9 opinions
- McConkey Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1952
- Miami Valley Coated Paper Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1954
- Superheater Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1942
- Foster Wheeler Corp. v. CommissionerUnited States Board of Tax Appeals · 1939
- Haas v. CommissionerUnited States Tax Court · 1953
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