Copco Steel & Engineering Co. v. Commissioner
United States Tax Court
Sec. 722 (b) (4), 1939 Code -- Change in Character of Business. -- Respondent allowed partial relief by reason of base period changes. Held, petitioner also qualifies for relief by reason of a change in capacity for production or operation consummated after December 31, 1939, by acquisition of leased facilities, as a result of a course of action to which petitioner was theretofore committed.
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Sec. 722 (b) (4), 1939 Code -- Change in Character of Business. -- Respondent allowed partial relief by reason of base period changes. Held, petitioner also qualifies for relief by reason of a change in capacity for production or operation consummated after December 31, 1939, by acquisition of leased facilities, as a result of a course of action to which petitioner was theretofore committed. Held, further, that certain other alleged committed-for changes in capacity are not established. Determination made of a fair and just amount representing normal earnings to be used as petitioner's…
1Opinion of the Court
Copco Steel and Engineering Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Copco Steel & Engineering Co. v. Commissioner
Docket No. 31716
United States Tax Court
31 T.C. 629; 1958 U.S. Tax Ct. LEXIS 3;
December 31, 1958, Filed
Decision will be entered under Rule 50.
Sec. 722 (b) (4), 1939 Code -- Change in Character of Business. -- Respondent allowed partial relief by reason of base period changes. Held, petitioner also qualifies for relief by reason of a change in capacity for production or operation consummated after December 31, 1939, by acquisition of leased facilities, as…
2Cases cited7 opinions
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- Crowell-Collier Pub. Co. v. CommissionerUnited States Tax Court · 1956
- Robinson Terminal Warehouse Corp. v. CommissionerUnited States Tax Court · 1953
- Lansburgh & Bro. v. CommissionerUnited States Tax Court · 1958
- Peter J. Schweitzer, Inc. v. CommissionerUnited States Tax Court · 1958
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