Maryland Jockey Club of Baltimore City v. United States

ALBERT V. BRYAN, Circuit Judge.

Excess profits tax relief was denied the Maryland Jockey Club of Baltimore City, by the District Court, on moneys received in 1950 and 1953 from the Maryland Racing Commission, and on this appeal the taxpayer renews its assertion that the sums received in those years was “abnormal income” as defined and accorded advantages by section 456 of the Internal Revenue Code of 1939, as amended. 1 We think the taxpayer has sustained its position.

The relief given by the statute is the allocation of abnormal income received in one year to another year or years to which it…