British-American Tobacco C. v. Commissioner

Board of Tax Appeals

British-American Tobacco C. v. Commissioner

27 B.T.A. 226, 1932 BTA LEXIS 1103

CourtUnited States Board of Tax Appeals

DecidedDecember 6, 1932

DocketDocket No. 41224.

StatusPublished

Cited by2 cases

This text of 27 B.T.A. 226 (British-American Tobacco C. v. Commissioner) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

British-American Tobacco C. v. Commissioner, 27 B.T.A. 226, 1932 BTA LEXIS 1103 (bta 1932).

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Opinions

OPINION.

Sternhagen :

The respondent determined deficiencies of $12,600.20 for 1925 and $182,832 for 1926 in the income tax of the petitioner, a foreign corporation. The facts are stipulated and are, in essence, that in the years in question the petitioner received from the United States stipulated amounts of interest upon refunds of overpayments [227]*227of income and profits taxes paid for 1917, 1918, and 1919, which respondent has determined were within petitioner’s taxable income. This determination the petitioner challenges and cites Stoekholms Enskilda Bank, 25 B. T. A. 1328. That decision decides precisely the same issue; and in accordance therewith, the respondent’s determination is reversed.

Reviewed by the Board.

Judgment will be entered under Bule 50.

Teammell concurs in the result.

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OPINION.

Sternhagen :

The respondent determined deficiencies of $12,600.20 for 1925 and $182,832 for 1926 in the income tax of the petitioner, a foreign corporation. The facts are stipulated and are, in essence, that in the years in question the petitioner received from the United States stipulated amounts of interest upon refunds of overpayments [227]*227of income and profits taxes paid for 1917, 1918, and 1919, which respondent has determined were within petitioner’s taxable income. This determination the petitioner challenges and cites Stoekholms Enskilda Bank, 25 B. T. A. 1328. That decision decides precisely the same issue; and in accordance therewith, the respondent’s determination is reversed.

Reviewed by the Board.

Judgment will be entered under Bule 50.

Teammell concurs in the result.

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Bluebook (online)

27 B.T.A. 226, 1932 BTA LEXIS 1103, Counsel Stack Legal Research, https://law.counselstack.com/opinion/british-american-tobacco-c-v-commissioner-bta-1932.

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