Burwell Motor Co. v. Commissioner
United States Tax Court
Petitioner claimed relief under section 722 (b) (1), (2), (3), (4), and (5). It asserted in its applications as a ground for relief under subsection (b) (4) that in the model year of 1934 or 1935 it had changed its product, from Ford to Chevrolet, "and various other factors."
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Petitioner claimed relief under section 722 (b) (1), (2), (3), (4), and (5). It asserted in its applications as a ground for relief under subsection (b) (4) that in the model year of 1934 or 1935 it had changed its product, from Ford to Chevrolet, "and various other factors." After the statute of limitations barred new claims, petitioner asserted for the first time that in 1939 it became the exclusive Chevrolet dealer in its area, changed from a conservative to a volume operation, and expanded its facilities. Held: 1. Since the original applications asserted a specific ground for relief,…
1Opinion of the Court
Burwell Motor Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Burwell Motor Co. v. Commissioner
Docket No. 30459
United States Tax Court
29 T.C. 224; 1957 U.S. Tax Ct. LEXIS 45;
November 14, 1957, Filed
Decision will be entered for the respondent.
Petitioner claimed relief under section 722 (b) (1), (2), (3), (4), and (5). It asserted in its applications as a ground for relief under subsection (b) (4) that in the model year of 1934 or 1935 it had changed its product, from Ford to Chevrolet, "and various other factors." After the statute of limitations barred new claims,…
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- United States v. AndrewsSupreme Court of the United States · 1938
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