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Wisconsin Gas & Electric Co. v. United States, 322 U.S. 526 (1944)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Wisconsin Gas & Electric Co. v. United States, 322 U.S. 526 (1944)
Wisconsin Gas & Electric Co. v. United States No. 565 Argued March 10, 1944 Decided May 29, 1944 322 U.S. 526
CERTIORARI TO THE CIRCUIT COURT OF APPEALS
FOR THE ELEVENTH CIRCUIT
Syllabus
1. Payment made by a corporation of the tax levied by the Wisconsin Privilege Dividend Tax Act, held, for federal income tax purposes, not deductible from gross income of the corporation either under § 23(c) or § 23(d) of the Revenue Act of 1934. Pp. 529, 531.
2. The payments were not deductible under § 23(c) as "taxes paid," since, within the meaning of applicable Treasury Regulations, the tax was not "imposed" on the corporation. P. 529.
3. Nor were the payments deductible under § 23(d) as
taxes imposed upon a shareholder of the corporation upon his interest as shareholder which are paid by the corporation without reimbursement from the shareholder,
since, within the meaning of the section, the tax was not "paid by the corporation without reimbursement from the shareholder." P. 531.
138 F.2d 597 affirmed.
Certiorari, 321 U.S. 757, to review a judgment for the company, 46 F.Supp. 929, in a suit for a refund of federal income tax.
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Chicago: U.S. Supreme Court, "Syllabus," Wisconsin Gas & Electric Co. v. United States, 322 U.S. 526 (1944) in 322 U.S. 526 Original Sources, accessed November 22, 2024, http://originalsources.com/Document.aspx?DocID=RS1TWHDPQTNKXNZ.
MLA: U.S. Supreme Court. "Syllabus." Wisconsin Gas & Electric Co. v. United States, 322 U.S. 526 (1944), in 322 U.S. 526, Original Sources. 22 Nov. 2024. http://originalsources.com/Document.aspx?DocID=RS1TWHDPQTNKXNZ.
Harvard: U.S. Supreme Court, 'Syllabus' in Wisconsin Gas & Electric Co. v. United States, 322 U.S. 526 (1944). cited in 1944, 322 U.S. 526. Original Sources, retrieved 22 November 2024, from http://originalsources.com/Document.aspx?DocID=RS1TWHDPQTNKXNZ.
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