Legal Opinion

Central Inv. Corp. v. Commissioner

United States Tax Court

Decided July 30, 1947No. Docket No. 7959PublishedCited by 22 opinions

California franchise tax imposed for the privilege of doing business during 1944, which tax is measured by income realized in 1943, held to accrue and be deductible for Federal tax purposes in 1944.

1Opinion of the Court

OPINION.

Hill, Judge-.

The problem for our determination is whether the California franchise tax imposed for the privilege of doing business during 1944 is deductible for Federal tax purposes in 1944, as respondent contends, or is deductible in 1943, the year giving rise to the income which furnishes the measure for the tax, as petitioner contends.

California imposes a tax on corporations for the privilege of doing business in the state during a given year, which year of privilege is designated the “taxable year.” The tax so imposed is, with certain exceptions not here material, a percentage of…

2Cases cited3 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. Magruder v. SuppleeSupreme Court of the United States · 1942
  3. Durst Productions Corp. v. CommissionerUnited States Tax Court · 1947

3Cited by22 opinions

  1. Gorman Lumber Sales Co. v. CommissionerUnited States Tax Court · 1949
  2. Charles Schwab Corp. v. CommissionerUnited States Tax Court · 1996
  3. ACF-Brill Motors Co. v. CommissionerUnited States Tax Court · 1950
  4. Grace Bros., Inc. v. CommissionerUnited States Tax Court · 1948
  5. Epoch Food Service, Inc. v. CommissionerUnited States Tax Court · 1979

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