Napco Industries, Inc. v. Commissioner
United States Tax Court
Held, the petitioner failed to qualify for relief under section 722 (b) (4). The petitioner's business was not commenced immediately prior to the base period, nor was there a change in the character of the business during the base period. ABC Brewing Corp., 20 T. C. 515 (1953), followed.
1Opinion of the Court
OPINION.
TRAIN, Judge:
The petitioner claimed refunds of excess profits taxes under section 7221 as follows:
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The respondent denied the relief claimed, and determined excess profits tax deficiencies, payment of which had been deferred under section 710 (a) (5) for the years and in the amounts as follows:
Year ended Oet. SI Bmeess profits tap
1943___$67,392.20
1944_ 71,921.38
1945_ 68,266. 90
1946_ 11, 697.36
The petitioner’s application for relief under section 722 (c) was waived at the hearing. Petitioner’s original application for relief was based on section 722 (b) (4) and was…
2Cases cited4 opinions
- Triangle Raincoat Co. v. CommissionerUnited States Tax Court · 1952
- A B C Brewing Corp. v. CommissionerUnited States Tax Court · 1953
- Clermont Groves, Inc. v. CommissionerUnited States Tax Court · 1952
- Crowell-Collier Pub. Co. v. CommissionerUnited States Tax Court · 1956
3Cited by5 opinions
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- Coe Laboratories, Inc. v. CommissionerUnited States Tax Court · 1960
- Napco Industries, Inc. v. CommissionerUnited States Tax Court · 1958