Seggerman Nixon Corp. v. Commissioner
United States Tax Court
Sec. 722. -- Held: Relief denied. Petitioner has established neither that it qualifies for relief because of one or more of the factors specified in section 722 (b) nor that its average base period net income, as computed under section 713 (f), is an inadequate standard of normal earnings.
1Opinion of the Court
OPINION.
Tietjens, Judge:
The petitioner asks for relief pursuant to section 722 (a) and subparagraphs (2), (4), and (5) of section 722 (b), Internal Revenue Code of 1939,1 from allegedly excessive and discriminatory excess profits taxes for fiscal years ended in 1944, 1945, and 1946.
The petitioner computed its excess profits credit under the average earnings method. In order to qualify for relief under section 722 the petitioner must show that its average base period net income is an inadequate standard of normal earnings because of one or more of the factors specified in section 722 (b) and…
2Cases cited5 opinions
- Monarch Cap Screw & Mfg. Co. v. CommissionerUnited States Tax Court · 1945
- Harlan Bourbon & Wine Co. v. CommissionerUnited States Tax Court · 1950
- A. B. Frank Co. v. CommissionerUnited States Tax Court · 1952
- West Flagler Amusement Co. v. CommissionerUnited States Tax Court · 1954
- Blaisdell Pencil Co. v. CommissionerUnited States Tax Court · 1951
3Cited by11 opinions
- Tri-State Beverage Distributors, Inc. v. CommissionerUnited States Tax Court · 1957
- Miami Valley Coated Paper Co. v. CommissionerUnited States Tax Court · 1957
- Blue Diamond Coal Co. v. CommissionerUnited States Tax Court · 1959
- Interstate Milling Co. v. CommissionerUnited States Tax Court · 1959
- Northwest Casualty Co. v. CommissionerUnited States Tax Court · 1957
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