William B. Scaife & Sons Co. v. Commissioner
United States Board of Tax Appeals
Petitioner filed an original capital stock tax return for the year ended June 30, 1936, on July 29, 1936, in which it declared a capital stock valuation of $600,000. The period for filing such return expired on July 31, 1936. On September 3, 1936, petitioner submitted to the Commissioner an amended capital stock tax return for that year in which it declared a capital stock valuation of $1,000,000, representing that the lower value of $600,000 was reported in the original…
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Petitioner filed an original capital stock tax return for the year ended June 30, 1936, on July 29, 1936, in which it declared a capital stock valuation of $600,000. The period for filing such return expired on July 31, 1936. On September 3, 1936, petitioner submitted to the Commissioner an amended capital stock tax return for that year in which it declared a capital stock valuation of $1,000,000, representing that the lower value of $600,000 was reported in the original return by mistake. Held, that the valuation declared in the original return could not be changed in the amended return…
1Opinion of the Court
OPINION.
Smith:
This proceeding involves an income tax deficiency for 1936 in the amount of $1,946.63 and an excess profits tax deficiency for that year in the amount of $942.15. Petitioner alleges that the respondent erred (1) in adding to its income an overstatement of Pennsylvania capital stock tax in the amount of $1,919.97, and (2) in refusing to allow a declared capital stock value of $1,000,000 as a basis for computing its excess profits tax.
The first issue has been settled by stipulation filed at the hearing, the parties having stipulated that petitioner is entitled to a deduction from…
2Cases cited2 opinions
- Haggar Co. v. Helvering, Com'r of Internal RevenueSupreme Court of the United States · 1940
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