Steel or Bronze Piston Ring Corp. v. Commissioner
United States Tax Court
1. Relief under section 721, Internal Revenue Code, denied to manufacturer of piston rings in the absence of proof that petitioner's income for 1942 and 1943 was due in any material part to the development of patents, formulae, and manufacturing processes in prior years, rather than to an increased wartime demand for petitioner's products. 2. Respondent sustained on other issues for lack of proof showing error in his determination.
1Opinion of the Court
OPINION.
LeMiRE, Judge:(1) Belief wider section 721. — It is petitioner’s contention that all of its 1942 and 1943 income resulted from research and development of tangible property, patents, formulae, and processes extending over the period beginning not later than 1929 and ending about 1936 or 1937, and was therefore'abnormal income within the meaning of section 721 (a) (1) and of the class described in subsection (a) (2) (C).
In our opinion the evidence fails to support this contention. From its inception the petitioner, largely through its president, conducted a certain amount of research…
2Cases cited3 opinions
- Soabar Co. v. CommissionerUnited States Tax Court · 1946
- Ramsey Accessories Mfg. Corp. v. CommissionerUnited States Tax Court · 1948
- Pantasote Leather Co. v. CommissionerUnited States Tax Court · 1949
3Cited by23 opinions
- Crowell-Collier Pub. Co. v. CommissionerUnited States Tax Court · 1956
- Coe Laboratories, Inc. v. CommissionerUnited States Tax Court · 1960
- Givan v. CripeCourt of Appeals for the Seventh Circuit · 1951
- Breeze Corps. v. CommissionerUnited States Tax Court · 1951
- Seawright v. Comm'rUnited States Tax Court · 2001
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