Riss & Co. v. Commissioner
United States Tax Court
1. Held, the Tax Court has jurisdiction under sections 273(c) of the 1939 Code and 6861(c) of the 1954 Code to decide a question concerning interest on a deficiency, where the interest has been assessed in connection with the jeopardy assessment of the deficiency. 2. Held, further, section 6601(e) of the 1954 Code does not apply to taxes imposed by the 1939 Code, even though the net operating loss arises in a year governed by the 1954 Code. 3. Held, further, under the 1939…
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1. Held, the Tax Court has jurisdiction under sections 273(c) of the 1939 Code and 6861(c) of the 1954 Code to decide a question concerning interest on a deficiency, where the interest has been assessed in connection with the jeopardy assessment of the deficiency. 2. Held, further, section 6601(e) of the 1954 Code does not apply to taxes imposed by the 1939 Code, even though the net operating loss arises in a year governed by the 1954 Code. 3. Held, further, under the 1939 Code, interest on deficiencies eliminated by net operating loss carrybacks runs at least until the due dates of the…
1Opinion of the Court
OPINION
FORRESTER, Judge:
On August 11, 1965, respondent filed his computation in this docket number under Rule 50, in accordance with our Memorandum Findings of Fact and Opinion filed July 14, 1964, T.C. Memo. 1964-190. On September 9,1965, petitioner filed an objection to respondent’s computation insofar as it related to interest payable on 1952 and 1953 income tax deficiencies which, were eliminated by net operating loss carrybacks from 1954 and 1955. Subsequently, a hearing was held and briefs were submitted by the parties in support of their respective positions. (We shall hereinafter use…
2Cases cited11 opinions
- Manning v. Seeley Tube & Box Co.Supreme Court of the United States · 1950
- Fuller v. CommissionerUnited States Tax Court · 1953
- Estate of Mary Redding Shedd, First National Bank of Arizona, Trustee v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1963
- COMMISSIONER OF INT. REVENUE v. Kilpatrick's EstateCourt of Appeals for the Sixth Circuit · 1944
- Shedd v. CommissionerUnited States Tax Court · 1961
6 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Estate of Baumgardner v. CommissionerUnited States Tax Court · 1985
- Hudgins v. CommissionerUnited States Tax Court · 1970
- Transport Manufacturing & Equipment Co. v. CommissionerCourt of Appeals for the Eighth Circuit · 1970
- Papa v. CommissionerUnited States Tax Court · 1971
- Transport Manufacturing & Equipment Company, a Delaware Corporation, Transferee v. Commissioner of Internal Revenue, Transport Manufacturing & Equipment Company, an Illinois Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1970
8 more not listed; retrieve them via the Exa API.