# Ciba Pharmaceutical Products, Inc. v. Commissioner

> United States Tax Court · November 25, 1960 · 35 T.C. 337

URL: https://www.frixlaw.com/law-library/cases/4478978

## Case

- **Full name:** Ciba Pharmaceutical Products, Inc. v. Commissioner of Internal Revenue
- **Court:** United States Tax Court
- **Decided:** November 25, 1960
- **Citations:** 35 T.C. 337; 1960 U.S. Tax Ct. LEXIS 17
- **Precedential status:** Published
- **Opinion:** Concurrence by Mukdock
- **Judges:** Mulronet, Mukdock
- **Cited by:** 4 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4478978

## Opinion text

Mukdock, J., concurring: The petitioner argues a matter on brief not included in the issues raised for decision. It is an attempt to increase the amount stipulated as the average base period net income under the growth formula of section 713(f) by an amount allegedly representing an abnormal deduction for 1939. That is a standard issue rather than an issue arising under section 722. There are at least three answers to this contention: (1) It is not presented for decision by the pleadings; (2) the Tax Court has no jurisdiction; and (3) it is contrary to the stipulated facts.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4478978. Public record. Not legal advice.