Calvert Iron Works, Inc. v. Commissioner
United States Tax Court
1. The proof made fails to establish earnings during the last base period year sufficient in amount to result, under reconstruction, in credits greater than the amounts allowed by the respondent under section 713, Internal Revenue Code of 1939. 2. The amount of excess profits tax deferred under section 710 (a) (5) is a part of the deficiency for imposition of an addition for fraud under section 293 (b). 3. Failure to file a timely excess profits tax return for 1945 not shown…
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1. The proof made fails to establish earnings during the last base period year sufficient in amount to result, under reconstruction, in credits greater than the amounts allowed by the respondent under section 713, Internal Revenue Code of 1939. 2. The amount of excess profits tax deferred under section 710 (a) (5) is a part of the deficiency for imposition of an addition for fraud under section 293 (b). 3. Failure to file a timely excess profits tax return for 1945 not shown to have been due to reasonable cause.
1Opinion of the Court
Calvert Iron Works, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Calvert Iron Works, Inc. v. Commissioner
Docket No. 40207
United States Tax Court
26 T.C. 770; 1956 U.S. Tax Ct. LEXIS 135;
June 29, 1956, Filed
Decision will be entered under Rule 50.
1. The proof made fails to establish earnings during the last base period year sufficient in amount to result, under reconstruction, in credits greater than the amounts allowed by the respondent under section 713, Internal Revenue Code of 1939.
2. The amount of excess profits tax deferred under section 710 (a) (5) is a part of the…
2Cases cited13 opinions
- Spies v. United StatesSupreme Court of the United States · 1943
- Haywood Lumber & Mining Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1950
- Wisconsin Farmer Co. v. CommissionerUnited States Tax Court · 1950
- Plunkett v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1941
- Southeastern Finance Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
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