Legal Opinion

Union Parts Mfg. Co. v. Commissioner

United States Tax Court

Decided July 28, 1955No. Docket No. 29242Published

Petitioner, a screw machine parts manufacturer, experienced net operating losses for the fiscal period July 20, 1936, to June 30, 1937, and for the fiscal years ended June 30, 1938 and 1939. It showed a small profit for the fiscal year ended June 30, 1940. In 1939, it purchased machine tools capable of producing high precision parts.

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Petitioner, a screw machine parts manufacturer, experienced net operating losses for the fiscal period July 20, 1936, to June 30, 1937, and for the fiscal years ended June 30, 1938 and 1939. It showed a small profit for the fiscal year ended June 30, 1940. In 1939, it purchased machine tools capable of producing high precision parts. The increase in its sales during its last fiscal year, subsequent to the acquisition of the new machinery, was due to subcontracting work performed for aircraft companies. It claimed excess profits tax relief under section 722 (b) (4) for the fiscal years ended…

1Opinion of the Court

Union Parts Mfg. Co., Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Union Parts Mfg. Co. v. Commissioner

Docket No. 29242

United States Tax Court

24 T.C. 775; 1955 U.S. Tax Ct. LEXIS 127;

July 28, 1955, Filed

Decision will be entered for the respondent.

Petitioner, a screw machine parts manufacturer, experienced net operating losses for the fiscal period July 20, 1936, to June 30, 1937, and for the fiscal years ended June 30, 1938 and 1939. It showed a small profit for the fiscal year ended June 30, 1940. In 1939, it purchased machine tools capable of producing high precision…

2Cases cited9 opinions

  1. Wisconsin Farmer Co. v. CommissionerUnited States Tax Court · 1950
  2. East Texas Motor Freight Lines v. CommissionerUnited States Tax Court · 1946
  3. 7-Up Ft. Worth Co. v. CommissionerUnited States Tax Court · 1947
  4. Farmers Creamery Co. v. CommissionerUnited States Tax Court · 1952
  5. Pabst Air Conditioning Corp. v. CommissionerUnited States Tax Court · 1950

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