Eisenstadt Mfg. Co. v. Commissioner

Petitioner filed timely claims for relief for the fiscal years 1942 to 1946, inclusive, under section 722, referring specifically therein to subsections (b) (2), (b) (3) (A), and (b) (5). After the time for filing any wholly new claims for the fiscal years 1942 and 1943 had expired under section 322, petitioner also claimed relief for all years under section 722 (b) (4). Respondent treated the 722 (b) (4) claim as an amendment of the original claims, and after various examinations and conferences denied relief under 722. At the hearing, respondent stipulated that petitioner was entitled to…