Ex-Marine Guards, Inc. v. Commissioner
United States Tax Court
Petitioner was incorporated on September 20, 1940, for the purpose of furnishing guards to California industrial plants whose products were important to the national defense program. It had $ 600 of invested capital. It experienced a net operating loss during its first 15 months of operation but realized taxable income in 1942, 1943, and 1944. It claimed excess profits tax relief under section 722 (c) for such years.
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Petitioner was incorporated on September 20, 1940, for the purpose of furnishing guards to California industrial plants whose products were important to the national defense program. It had $ 600 of invested capital. It experienced a net operating loss during its first 15 months of operation but realized taxable income in 1942, 1943, and 1944. It claimed excess profits tax relief under section 722 (c) for such years. Held, even assuming that petitioner established the existence of the qualifying conditions for relief under such section, it failed to establish a basis for reconstruction of…
1Opinion of the Court
Ex-Marine Guards, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Ex-Marine Guards, Inc. v. Commissioner
Docket No. 37111
United States Tax Court
25 T.C. 524; 1955 U.S. Tax Ct. LEXIS 17;
December 16, 1955, Filed
Decision will be entered for the respondent.
Petitioner was incorporated on September 20, 1940, for the purpose of furnishing guards to California industrial plants whose products were important to the national defense program. It had $ 600 of invested capital. It experienced a net operating loss during its first 15 months of operation but realized taxable income in 1942,…
2Cases cited4 opinions
- Danco Co. v. CommissionerUnited States Tax Court · 1950
- Fezandie & Sperrle v. Comm'rUnited States Tax Court · 1945
- Harry Lang Mfg. Co. v. CommissionerUnited States Tax Court · 1952
- Ex-Marine Guards, Inc. v. CommissionerUnited States Tax Court · 1955