F. W. Poe Mfg. Co. v. Commissioner
United States Tax Court
Petitioner duly filed income and excess profits tax returns for its taxable years 1941 and 1942. Later it filed for the same years timely applications for relief under section 722 of the Internal Revenue Code of 1939. In 1944 it was furnished a copy of a report by a revenue agent which had allowed the applications in part but had made several other adjustments so that the net effect was a proposed determination of deficiencies in both income and excess profits taxes for both…
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Petitioner duly filed income and excess profits tax returns for its taxable years 1941 and 1942. Later it filed for the same years timely applications for relief under section 722 of the Internal Revenue Code of 1939. In 1944 it was furnished a copy of a report by a revenue agent which had allowed the applications in part but had made several other adjustments so that the net effect was a proposed determination of deficiencies in both income and excess profits taxes for both years. About a month later petitioner executed a waiver of restrictions on assessment and collection of deficiency in…
1Opinion of the Court
OPINION.
Arundell, Judge:
This proceeding now comes before us pursuant to mandate of the Court of Appeals for the Fourth Circuit, remanding the case for further proceedings not inconsistent with its per curiam opinion filed July 13, 1955. (224 F. 2d 254.)
In a Memorandum Findings of Fact and Opinion filed September 24, 1954, we held, on authority of Mutual Lumber Co., 16 T. C. 370, that we were without jurisdiction to consider issues raised by either litigant relating to the general provisions of the excess profits tax statute and, by order entered September 28, 1954, we dismissed the proceeding…
2Cases cited5 opinions
- Lewis v. ReynoldsSupreme Court of the United States · 1932
- Rothensies v. Electric Storage Battery Co.Supreme Court of the United States · 1946
- Mutual Lumber Co. v. CommissionerUnited States Tax Court · 1951
- H. Fendrich, Inc. v. CommissionerUnited States Tax Court · 1955
- Commissioner of Internal Revenue v. F. W. Poe Manufacturing CompanyCourt of Appeals for the Fourth Circuit · 1955
3Cited by13 opinions
- Overland Corp. v. CommissionerUnited States Tax Court · 1960
- Commissioner of Internal Revenue v. The S. Frieder & Sons Company, the S. Frieder & Sons Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1957
- May Broadcasting Co. v. CommissionerUnited States Tax Court · 1960
- Connecticut Light & Power Co. v. CommissionerUnited States Tax Court · 1963
- Central Paper Co. v. CommissionerUnited States Tax Court · 1958
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