Legal Opinion

Standard Tube Co. v. Commissioner

United States Tax Court

Decided August 13, 1956No. Docket No. 33386PublishedCited by 1 opinion

Held, petitioner has failed to justify a constructive average base period net income under section 722 (b) (4), I. R. C. 1939, in excess of that allowed it by respondent.

1Opinion of the Court

OPINION.

Beuoe, Judge:

Petitioner’s actual average base period net income was a loss figure of $104,947.91.1 Respondent admits that the elimination during the base period of petitioner’s seamless tube mill, the addition of new agencies to diversify its customers and geographic area, and the change to an electric resistance welding process for its tube manufacture constituted qualifying factors under section 722 (b) (4) of the Internal Revenue Code of 1939, and has allowed petitioner a constructive average base period net income of $91,550 for 1943, 1944, and 1945. Petitioner had computed its…

2Cases cited1 opinion

  1. Nivison-Weiskopf Co. v. CommissionerUnited States Tax Court · 1952

3Cited by1 opinion

  1. Standard Tube Co. v. CommissionerUnited States Tax Court · 1956

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