L. E. Carpenter & Co. v. Commissioner
United States Tax Court
Prior to 1941, the petitioner was a producer of book cloth, a chemically coated or impregnated fabric. In 1941 petitioner converted to the production of tent material for the Government. Held, under the record presented, the petitioner has not shown that any part of the income received from the production of tent material for the Government can be attributed to research and development in prior years within the meaning of section 721 (a) (2) (C), I. R. C. 1939.
1Opinion of the Court
MulRoney, Judge:
This is a proceeding involving deficiencies asserted by the respondent and refunds claimed by the petitioner as follows:
[[Image here]]
The sole issue presented for our determination is whether petitioner derived abnormal income during the taxable years 1942 through 1945 which can be attributed to its prewar research and development extending over a period of more than 12 months within the meaning of section 721 (a) (2) (C) of the Internal Revenue Code of 1939.
FINDINGS OF FACT.
Some of the facts have been stipulated and are found accordingly.
L. E. Carpenter & Company, hereinafter…
2Cases cited2 opinions
- Pantasote Leather Co. v. CommissionerUnited States Tax Court · 1949
- Phillips v. RothwellCourt of Appeals of Kentucky · 1819
3Cited by6 opinions
- Sprague Electric Co. v. CommissionerUnited States Tax Court · 1961
- L. E. Carpenter & Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1959
- Overland Corp. v. CommissionerUnited States Tax Court · 1964
- L. E. Carpenter & Co. v. CommissionerUnited States Tax Court · 1957
- Overland Corp. v. CommissionerUnited States Tax Court · 1964
1 more not listed; retrieve them via the Exa API.