Powell-Hackney Grocery Co. v. Commissioner
United States Tax Court
Petitioner has failed to establish that any portion of its 1943 abnormal income was attributable to any other years, entitling it to relief under section 721 of the Internal Revenue Code.
1Opinion of the Court
OPINION.
Hill, Judge:
The sole issue is whether petitioner is entitled to any relief under section 721 of the Internal Eevenue Code.
In Producers Crop Improvement Association, 7 T. C. 562, we outlined the three steps necessary to establish the right to relief under section 721 of the Code: (1) a showing of the amount of abnormal income in the taxable year; (2) the abnormal net income derived therefrom; and (3) the portion of abnormal net income attributable to other taxable years.
The respondent contends that petitioner has failed to establish any of the three aforementioned steps. What…
2Cases cited4 opinions
- Soabar Co. v. CommissionerUnited States Tax Court · 1946
- Producers Crop Improv. Asso. v. CommissionerUnited States Tax Court · 1946
- Morrisdale Coal Mining Co. v. CommissionerUnited States Tax Court · 1949
- Primas Groves, Inc. v. CommissionerUnited States Tax Court · 1950
3Cited by11 opinions
- Crowell-Collier Pub. Co. v. CommissionerUnited States Tax Court · 1956
- Central Bag Co. v. CommissionerUnited States Tax Court · 1956
- E. W. Williams Publications, Inc. v. CommissionerUnited States Tax Court · 1955
- White v. CommissionerUnited States Tax Court · 1957
- Central Bag Co. v. CommissionerUnited States Tax Court · 1956
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