Breeze Corps. v. Commissioner
United States Tax Court
The petitioner filed claim for relief as to excess profits taxes under section 721 (a) (2) (C) of the Internal Revenue Code, on the ground that income for 1941 was abnormal in amount. Held, claim denied for the reason that the claimed net abnormal income for 1941 was the result of increased physical volume of sales due to increased demand, and therefore under Regulations 112, section 35.721-3, was not attributable to earlier years.
1Opinion of the Court
OPINION.
Disney, Judge:
Our only question is whether the petitioner received during the taxable year 1941 from the sale of rotating antenna mounts and armor plate net abnormal income that was attributable to any previous taxable year or years so as to be entitled to relief for the taxable year 1941 under the provisions of section 721 (a) (1) and (a) (2) (C) of the Internal Revenue Code.1
The petitioner contends that in 1941 it had gross profit from antenna mounts and armor plate in the amount of $2,021,962; that since its average therefrom in 1937-1940, inclusive, was a minus figure, 125 per…
2Cases cited7 opinions
- Soabar Co. v. CommissionerUnited States Tax Court · 1946
- Differential Steel Car Co. v. Comm'rUnited States Tax Court · 1951
- Steel or Bronze Piston Ring Corp. v. CommissionerUnited States Tax Court · 1949
- Keystone Brass Works v. CommissionerUnited States Tax Court · 1949
- Pantasote Leather Co. v. CommissionerUnited States Tax Court · 1949
2 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Ohio Machine Tool Co. v. CommissionerUnited States Tax Court · 1952
- Sprague Electric Co. v. CommissionerUnited States Tax Court · 1961
- Sprague Electric Company v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1964
- Breeze Corps. v. CommissionerUnited States Tax Court · 1951
- Ohio Machine Tool Co. v. CommissionerUnited States Tax Court · 1952
1 more not listed; retrieve them via the Exa API.