Stimson Mill Co. v. Commissioner
United States Tax Court
The petitioner, in calculation of excess profits tax for 1942, because of a strike in 1937 reconstructed income for that year under section 722, Internal Revenue Code; and, under section 713 (e) (1), Internal Revenue Code, it increased excess profits net income for 1938, the base period year of lowest income, to 75 per cent of the average for 1936, 1937, and 1939, using the reconstructed figure for 1937, and claimed excess profits tax credit based upon the result of such…
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The petitioner, in calculation of excess profits tax for 1942, because of a strike in 1937 reconstructed income for that year under section 722, Internal Revenue Code; and, under section 713 (e) (1), Internal Revenue Code, it increased excess profits net income for 1938, the base period year of lowest income, to 75 per cent of the average for 1936, 1937, and 1939, using the reconstructed figure for 1937, and claimed excess profits tax credit based upon the result of such calculations. The Commissioner allowed computation of the four-year base period average after increase of 1938 income to 75…
1Opinion of the Court
OPINION.
Disney, Judge-.
The Commissioner determined a deficiency of $2,106.08 in excess profits tax for the year 194Í2 as a result of denying to the petitioner relief under section 722 of the Internal Revenue Code. The only issue is whether petitioner is entitled to relief under section 722 of the Internal Revenue Code, in addition to the benefits of section 713 (e) (1) of the code.
The facts have all been stipulated. We adopt the stipulation as our findings of fact. Omitting formal parts and matters not considered material to examination of the issue, the stipulation reads:
1. The petitioner is…
2Cases cited1 opinion
- Monarch Cap Screw & Mfg. Co. v. CommissionerUnited States Tax Court · 1945
3Cited by30 opinions
- Homer Laughlin China Co. v. CommissionerUnited States Tax Court · 1946
- Brown Paper Mill Co. v. CommissionerUnited States Tax Court · 1954
- Dowd-Feder, Inc. v. CommissionerUnited States Tax Court · 1948
- Midvale Co. v. CommissionerUnited States Tax Court · 1953
- Block One Thirty-Nine, Inc. v. CommissionerUnited States Tax Court · 1952
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