Hummel & Downing Co. v. Commissioner
United States Tax Court
Application for Relief Under Section 722 -- Sufficiency of Applications for Relief. -- The Tax Court will not consider as a possible basis for relief under section 722 a contention and supporting facts presented to it which were not a part of the Form 991 applications shown to the Court and which the petitioner fails to show were ever properly advanced for the Commissioner's consideration prior to his denial of the applications.
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Application for Relief Under Section 722 -- Sufficiency of Applications for Relief. -- The Tax Court will not consider as a possible basis for relief under section 722 a contention and supporting facts presented to it which were not a part of the Form 991 applications shown to the Court and which the petitioner fails to show were ever properly advanced for the Commissioner's consideration prior to his denial of the applications. Blum Folding Paper Box Co., 4 T. C. 795, followed.
1Opinion of the Court
OPINION.
Murdock, Judge:
The petitioner was a wholly owned subsidiary of Corn Products Refining Company at all times material hereto prior to December 1, 1941, when it was purchased by Cornell Wood Products Company.
The petitioner had been engaged for many years in manufacturing and selling paper board containers and it manufactured two types of paper board which it used in the construction of the containers. One type of paper board which it manufactured was called jute liner board which consists, by weight, of approximately 75 per cent waste paper and 25 per cent kraft pulp. Kraft pulp is a…
2Cases cited7 opinions
- Angelus Milling Co. v. CommissionerSupreme Court of the United States · 1945
- Monarch Cap Screw & Mfg. Co. v. CommissionerUnited States Tax Court · 1945
- Blum Folding Paper Box Co. v. CommissionerUnited States Tax Court · 1945
- Wadley Co. v. CommissionerUnited States Tax Court · 1951
- Alexandria Amusement Corp. v. CommissionerUnited States Tax Court · 1951
2 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Pelton & Crane Co. v. CommissionerUnited States Tax Court · 1953
- Telfair Stockton & Co. v. CommissionerUnited States Tax Court · 1953
- Hummel & Downing Co. v. CommissionerUnited States Tax Court · 1953
- Metal Hose & Tubing Co. v. CommissionerUnited States Tax Court · 1953
- Hummel & Downing Co. v. CommissionerUnited States Tax Court · 1953
5 more not listed; retrieve them via the Exa API.