Legal Opinion

Breeze Corps. v. Commissioner

United States Tax Court

Decided March 8, 1951No. Docket No. 20975Published

The petitioner filed claim for relief as to excess profits taxes under section 721 (a) (2) (C) of the Internal Revenue Code, on the ground that income for 1941 was abnormal in amount. Held, claim denied for the reason that the claimed net abnormal income for 1941 was the result of increased physical volume of sales due to increased demand, and therefore under Regulations 112, section 35.721-3, was not attributable to earlier years.

1Opinion of the Court

Breeze Corporations, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Breeze Corps. v. Commissioner

Docket No. 20975

United States Tax Court

16 T.C. 587; 1951 U.S. Tax Ct. LEXIS 250;

March 8, 1951, Promulgated

Decision will be entered for the respondent.

The petitioner filed claim for relief as to excess profits taxes under section 721 (a) (2) (C) of the Internal Revenue Code, on the ground that income for 1941 was abnormal in amount. Held, claim denied for the reason that the claimed net abnormal income for 1941 was the result of increased physical volume of sales due to increased…

Also in this document: Dissent.

2Cases cited8 opinions

  1. Soabar Co. v. CommissionerUnited States Tax Court · 1946
  2. Differential Steel Car Co. v. Comm'rUnited States Tax Court · 1951
  3. Steel or Bronze Piston Ring Corp. v. CommissionerUnited States Tax Court · 1949
  4. Keystone Brass Works v. CommissionerUnited States Tax Court · 1949
  5. Pantasote Leather Co. v. CommissionerUnited States Tax Court · 1949

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