F. & D. Rentals, Inc. v. Commissioner of Internal Revenue

HASTINGS, Chief Judge.

Petitioner, F. & D. Rentals, Inc. (F & D), an Indiana corporation, appeals from an adverse decision of the Tax Court of the United States1 which upheld the determination by the Commissioner of Internal Revenue of a $98,540.50 deficiency in F & D’s income tax for the fiscal year ended April 30, 1958.

F & D was first organized in 1957 under the name of The South Bend Toy Manufacturing, Inc., for the purpose of engaging in the manufacture and sale of toys.2 This was the same name as that of an Indiana corporation organized in 1882 for the purpose of engaging in the…