Seed v. Commissioner

U.S. Tax Court

Seed v. Commissioner

24 T.C. 1131

CourtUnited States Tax Court

DecidedSeptember 29, 1955

DocketDocket No. 50073

StatusPublished

This text of 24 T.C. 1131 (Seed v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Seed v. Commissioner, 24 T.C. 1131 (tax 1955).

Pincite

Opinion

OPINION.

Raum, Judge:

Petitioner seeks the benefit of an unused excess profits credit carry-over based on a constructive average base period net income from its fiscal year 1941 to its fiscal year 1942, notwithstanding that it made no claim for such carry-over in its application for relief which it filed with respect to 1942. This issue is foreclosed by the decision of this Court in Lockhart Creamery, 17 T. C. 1123, 1140-1143. Cf. St. Louis Amusement Co., 22 T. C. 522; Barry-Wehmiller Machinery Co., 20 T. C. 705.

Reviewed by the Special Division.

Decision will he entered for the respondent.

Free access — add to your briefcase to read the full text and ask questions with AI

OPINION.

Raum, Judge:

Petitioner seeks the benefit of an unused excess profits credit carry-over based on a constructive average base period net income from its fiscal year 1941 to its fiscal year 1942, notwithstanding that it made no claim for such carry-over in its application for relief which it filed with respect to 1942. This issue is foreclosed by the decision of this Court in Lockhart Creamery, 17 T. C. 1123, 1140-1143. Cf. St. Louis Amusement Co., 22 T. C. 522; Barry-Wehmiller Machinery Co., 20 T. C. 705.

Reviewed by the Special Division.

Decision will he entered for the respondent.

Cite This Page — Counsel Stack

Bluebook (online)

24 T.C. 1131, Counsel Stack Legal Research, https://law.counselstack.com/opinion/seed-v-commissioner-tax-1955.

Opinion

Related

Cite This Page — Counsel Stack