El Campo Rice Milling Co. v. Commissioner
United States Tax Court
The taxpayer corporation has operated a rice mill since 1903, purchasing rough rice from farmers, milling it, and selling the milled product through brokers. The business is very competitive and speculative; there is no central market; no crop or price statistics are currently published; and the capacity of existing mills exceeds processing needs.
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The taxpayer corporation has operated a rice mill since 1903, purchasing rough rice from farmers, milling it, and selling the milled product through brokers. The business is very competitive and speculative; there is no central market; no crop or price statistics are currently published; and the capacity of existing mills exceeds processing needs. Earnings depend largely on inventory position in relation to market trends, and the taxpayer's income experience has shown violent fluctuations, comprising large profits and heavy losses without visible relation to the prices of rough and milled…
1Opinion of the Court
OPINION.
Johnson, Judge:
Petitioner charges respondent with error in refusing to grant any relief in respect of its excess profits taxes for the fiscal years ended June 80, 1941, 1942, 1943, and 1944, arguing that the grounds urged in its rejected applications entitle it to the benefits of section 722, Internal Revenue Code. This section was designed to “afford relief in meritorious cases to corporations which bear an excessive tax burden because of an abnormally low excess profits tax credit.” Senate Finance Committee Rept. No. 1631, 77th Cong., 2d sess. By subsection (a) 1 a taxpayer who…
2Cases cited4 opinions
- Lamar Creamery Co. v. CommissionerUnited States Tax Court · 1947
- Monarch Cap Screw & Mfg. Co. v. CommissionerUnited States Tax Court · 1945
- Irwin B. Schwabe Co. v. CommissionerUnited States Tax Court · 1949
- Fish Net & Twine Co. v. CommissionerUnited States Tax Court · 1947
3Cited by29 opinions
- Avey Drilling Machine Co. v. CommissionerUnited States Tax Court · 1951
- Foskett & Bishop Co. v. CommissionerUnited States Tax Court · 1951
- Ray Campbell, Wise & Wright, Inc. v. CommissionerUnited States Tax Court · 1950
- Monarch Mfg. Co. v. CommissionerUnited States Tax Court · 1950
- Orangeburg Mfg. Co. v. CommissionerUnited States Tax Court · 1961
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