Rockford Screw Products Co. v. Commissioner
United States Tax Court
1. Petition for review of disallowance of claim for refund amplifying claim for accelerated depreciation of emergency facilities under section 124, Internal Revenue Code, and relating to disallowance of adjustments provided for in section 711 (b) (1) (J), held within the jurisdiction of the Tax Court under section 732, Internal Revenue Code. 2. A claim filed, after the statutory period, to amplify an earlier timely claim which had not yet been properly disallowed held, on…
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1. Petition for review of disallowance of claim for refund amplifying claim for accelerated depreciation of emergency facilities under section 124, Internal Revenue Code, and relating to disallowance of adjustments provided for in section 711 (b) (1) (J), held within the jurisdiction of the Tax Court under section 732, Internal Revenue Code. 2. A claim filed, after the statutory period, to amplify an earlier timely claim which had not yet been properly disallowed held, on facts, not untimely. 3. Petitioner's abnormal base period expenses for interest on notes issued as dividends held, on…
1Opinion of the Court
OPINION.
I
Opper, Judge,:
Respondent issued a timely notice of deficiency with respect to petitioner’s excess profits tax for the fiscal year 1946. In its petition placing that deficiency in issue petitioner also complained of respondent’s failure to act favorably on claims for refund which petitioner had filed with respect to fiscal years 1943 and 1944 based upon a recomputation of its accelerated amortization pursuant to the subsequent Presidential proclamation issued following the conclusion of World War II. That claim has never been rejected as untimely and would have been allowed in full…
2Cases cited17 opinions
- United States v. Memphis Cotton Oil Co.Supreme Court of the United States · 1933
- Tait v. Western Maryland Railway Co.Supreme Court of the United States · 1933
- United Business Corporation v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1933
- William Leveen Corp. v. CommissionerUnited States Tax Court · 1944
- Green Bay Lumber Co. v. CommissionerUnited States Tax Court · 1944
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3Cited by1 opinion
- Rockford Screw Products Co. v. CommissionerUnited States Tax Court · 1954