Franks Mfg. Corp. v. Commissioner
United States Tax Court
Changes in the types of oil well drilling and servicing equipment manufactured by petitioner held a change in the character of the business under section 722 (b) (4), I. R. C. 1939, and a constructive average base period net income determined.
1Opinion of the Court
OPINION.
Withet, Judge:
Petitioner’s claims for relief are based on section 722 (b) (4), Internal Revenue Code of 1939. It contends that there was a change in the character of its business during the base period years when it began the manufacture and sale of portable rotary drilling rigs and telescoping derricks.
Respondent has recognized that petitioner is entitled to have its excess profits tax computed on a constructive average base period net income of $8,700, which produces a credit slightly in excess of that computed under the invested capital method for 1941 but less than that for the…
2Cases cited1 opinion
- Godfrey Food Co. v. CommissionerUnited States Tax Court · 1952
3Cited by1 opinion
- Franks Mfg. Corp. v. CommissionerUnited States Tax Court · 1956