Wentworth Military, Scientific & Literary Educational Co. v. Commissioner
United States Tax Court
Petitioner operates a military school for boys. It filed claims for relief under section 722 of the Internal Revenue Code for the years ended June 30, 1943, to June 30, 1946, inclusive. Held, petitioner is not entitled to relief under section 722 (a) and (b) (4) of the Code.
1Opinion of the Court
OPINION.
LeMiee, Judge:
The question presented is whether the petitioner is entitled to any relief from excess profits taxes for the fiscal years ended June 30, 1943, to June 30, 1946, inclusive, under the provisions of section 722 of the Internal Revenue Code.
We are convinced that the record establishes that the petitioner changed the character of its business during the base period years within the meaning of section 722 (a) and (b) (4) of the Code. The essential nature of the changes was the institution of new key managing personnel and the adoption of new basic management policies in the…
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