Miami Valley Coated Paper Co. v. Commissioner
United States Tax Court
1. There having been no waiver of regulatory requirements by the Commissioner and no administrative action having been taken on a claim under section 722 (b) (4) first made on August 8, 1952, whereas the notice of disallowance of claims under section 722 had been issued June 9, 1950, this Court has no jurisdiction to consider the subsection (b) (4) claim. 2. Petitioner has not shown that it is entitled to relief under section 722 (b) (1) or (b) (2). 3. Petitioner has not…
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1. There having been no waiver of regulatory requirements by the Commissioner and no administrative action having been taken on a claim under section 722 (b) (4) first made on August 8, 1952, whereas the notice of disallowance of claims under section 722 had been issued June 9, 1950, this Court has no jurisdiction to consider the subsection (b) (4) claim. 2. Petitioner has not shown that it is entitled to relief under section 722 (b) (1) or (b) (2). 3. Petitioner has not shown error in the Commissioner's disallowance of certain claimed deductions.
1Opinion of the Court
Tietjens, Judge:
This case involves refunds of excess profits tax claimed by petitioner in applications for relief under section 722 of the Internal Revenue Code of 1939 and deficiencies in excess profits tax arising from so-called standard issues for the years 1944, 1945, and 1946.
The Commissioner disallowed the claims for refund and determined deficiencies in excess profits tax as follows:
Tear ended April SO Deficiency
1944-$19,499.48
1945-1- 3, 817.10
1946- 4, 776.26
The petitioner claims relief under section 722 (b) (1), (2), and (4). The Commissioner contends that this Court has no…
2Cases cited9 opinions
- Monarch Cap Screw & Mfg. Co. v. CommissionerUnited States Tax Court · 1945
- Blum Folding Paper Box Co. v. CommissionerUnited States Tax Court · 1945
- Harlan Bourbon & Wine Co. v. CommissionerUnited States Tax Court · 1950
- Toledo Stove & Range Co. v. CommissionerUnited States Tax Court · 1951
- A. B. Frank Co. v. CommissionerUnited States Tax Court · 1952
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3Cited by13 opinions
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- A. Finkl & Sons Co. v. CommissionerUnited States Tax Court · 1962
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