Baltimore Transfer Co. v. Commissioner
United States Tax Court
Petitioner, on the accrual basis, computed and accrued its 1943 liability under the Maryland Unemployment Compensation Law pursuant to rate notification by the administering state board and paid the accrued amounts prior to filing its 1943 tax returns on March 15, 1944. On April 21, 1944, the board, following an opinion of its counsel on a general question of law, notified petitioner that its correct rate was less than that originally determined.
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Petitioner, on the accrual basis, computed and accrued its 1943 liability under the Maryland Unemployment Compensation Law pursuant to rate notification by the administering state board and paid the accrued amounts prior to filing its 1943 tax returns on March 15, 1944. On April 21, 1944, the board, following an opinion of its counsel on a general question of law, notified petitioner that its correct rate was less than that originally determined. On May 15, 1944, petitioner's account was accordingly credited with a portion of the payments for 1943. Petitioner had not questioned the…
1Opinion of the Court
OPINION.
Hill, Judge:
Respondent determined deficiencies in petitioner’s income tax and excess profits tax liabilities for the calendar year 1943 in the respective amounts of $4,260.03 and $347.31. Only a portion of the deficiencies is in controversy. The sole question presented is whether petitioner is entitled to deduct an amount accrued by it in the taxable year as due to the Maryland Unemployment Compensation Fund, which amount was subsequently paid but was refunded to petitioner in 1944. The facts are stipulated and are so found.
Petitioner is a Maryland corporation organized in 1892 and…
2Cases cited11 opinions
- Chicot County Drainage District v. Baxter State BankSupreme Court of the United States · 1940
- United States v. AndersonSupreme Court of the United States · 1926
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
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3Cited by46 opinions
- Stamos v. CommissionerUnited States Tax Court · 1954
- Electric Tachometer Corp. v. CommissionerUnited States Tax Court · 1961
- Taylor Instrument Cos. v. CommissionerUnited States Tax Court · 1950
- Bartlett v. DelaneyCourt of Appeals for the First Circuit · 1949
- Country Club Estates, Inc. v. CommissionerUnited States Tax Court · 1954
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