Legal Opinion

Merrimac Hat Corp. v. Commissioner

United States Tax Court

Decided August 18, 1959No. Docket No. 50382Published

Section 3807, 1939 Code: Respondent allowed excess profits tax relief under section 722 for 1942 which resulted in decrease of excess profits net income and excess profits tax, and overpayment of tax in the gross amount of $ 64,366.21, of which $ 17,070.45 was refundable under sections 729(a) and 322(b). Section 3807 permitted respondent's adjustment of the 1942 income tax otherwise barred by section 275 but made necessary by the change in the related excess profits tax.

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Section 3807, 1939 Code: Respondent allowed excess profits tax relief under section 722 for 1942 which resulted in decrease of excess profits net income and excess profits tax, and overpayment of tax in the gross amount of $ 64,366.21, of which $ 17,070.45 was refundable under sections 729(a) and 322(b). Section 3807 permitted respondent's adjustment of the 1942 income tax otherwise barred by section 275 but made necessary by the change in the related excess profits tax. Under such adjustment there was an income tax deficiency of $ 31,785.78, which was less than the gross amount of the…

1Opinion of the Court

Merrimac Hat Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Merrimac Hat Corp. v. Commissioner

Docket No. 50382

United States Tax Court

32 T.C. 1082; 1959 U.S. Tax Ct. LEXIS 104;

August 18, 1959, Filed

Decision will be entered under Rule 50.

Section 3807, 1939 Code: Respondent allowed excess profits tax relief under section 722 for 1942 which resulted in decrease of excess profits net income and excess profits tax, and overpayment of tax in the gross amount of $ 64,366.21, of which $ 17,070.45 was refundable under sections 729(a) and 322(b). Section 3807 permitted…

2Cases cited1 opinion

  1. Merrimac Hat Corp. v. CommissionerUnited States Tax Court · 1959

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