Feature Publications, Inc. v. Commissioner
United States Tax Court
Petitioner filed timely applications for relief under section 722, I. R. C. 1939, for its fiscal years 1943 and 1944, but no mention was made of carryover or carryback of unused excess profits tax credits from other years to either 1943 or 1944. After the statute of limitations had run, petitioner filed so-called amended applications asking for unused excess profits credit carryovers from 1941 and 1942 and carryback from 1946 based on requested section 722 determinations for…
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Petitioner filed timely applications for relief under section 722, I. R. C. 1939, for its fiscal years 1943 and 1944, but no mention was made of carryover or carryback of unused excess profits tax credits from other years to either 1943 or 1944. After the statute of limitations had run, petitioner filed so-called amended applications asking for unused excess profits credit carryovers from 1941 and 1942 and carryback from 1946 based on requested section 722 determinations for each of those years. Held, that the amended applications were barred by the statute of limitations.
1Opinion of the Court
Feature Publications, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Feature Publications, Inc. v. Commissioner
Docket No. 41911
United States Tax Court
29 T.C. 313; 1957 U.S. Tax Ct. LEXIS 38;
November 20, 1957, Filed
Decision will be entered under Rule 50.
Petitioner filed timely applications for relief under section 722, I. R. C. 1939, for its fiscal years 1943 and 1944, but no mention was made of carryover or carryback of unused excess profits tax credits from other years to either 1943 or 1944. After the statute of limitations had run, petitioner filed so-called amended…
2Cases cited20 opinions
- United States v. Memphis Cotton Oil Co.Supreme Court of the United States · 1933
- Angelus Milling Co. v. CommissionerSupreme Court of the United States · 1945
- United States v. Garbutt Oil Co.Supreme Court of the United States · 1938
- United States v. AndrewsSupreme Court of the United States · 1938
- Blum Folding Paper Box Co. v. CommissionerUnited States Tax Court · 1945
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