Legal Opinion

Welch Grape Juice Co. v. Commissioner

United States Tax Court

Decided October 28, 1947No. Docket No. 9571Published

Where petitioner seeks to exclude a number of deductions in the computation of its base period net income and the Commissioner denies the propriety of such exclusion, the petitioner, after amending its petition, may establish by evidence its right to such exclusion in the last two years of said base period and accede to the Commissioner's rejection thereof in the first two years, where the exclusions of the last two years of the base period fall in a class differing from…

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Where petitioner seeks to exclude a number of deductions in the computation of its base period net income and the Commissioner denies the propriety of such exclusion, the petitioner, after amending its petition, may establish by evidence its right to such exclusion in the last two years of said base period and accede to the Commissioner's rejection thereof in the first two years, where the exclusions of the last two years of the base period fall in a class differing from that of the exclusions originally claimed for the first two years thereof, even though the petitioner procures a tax…

1Opinion of the Court

The Welch Grape Juice Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Welch Grape Juice Co. v. Commissioner

Docket No. 9571

United States Tax Court

9 T.C. 786; 1947 U.S. Tax Ct. LEXIS 53;

October 28, 1947, Promulgated

Decision will be entered under Rule 50.

Where petitioner seeks to exclude a number of deductions in the computation of its base period net income and the Commissioner denies the propriety of such exclusion, the petitioner, after amending its petition, may establish by evidence its right to such exclusion in the last two years of said base period and accede to the…

2Cases cited4 opinions

  1. R. C. Harvey Co. v. CommissionerUnited States Tax Court · 1945
  2. Colson Corp. v. CommissionerUnited States Tax Court · 1945
  3. Welch Grape Juice Co. v. CommissionerUnited States Tax Court · 1947
  4. Fain Drilling Co. v. CommissionerUnited States Tax Court · 1947

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