Sommerfeld Machine Co. v. Commissioner
United States Tax Court
1. Petitioner's receipt of income from manufacture and sale of lathes developed in prior years over a period in excess of 12 months held to entitle petitioner to special relief from excess profits tax under Internal Revenue Code, section 721 (a) (2) (C), with adjustments for expenses deductible in computing net abnormal income, and after application of business improvement factor.
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1. Petitioner's receipt of income from manufacture and sale of lathes developed in prior years over a period in excess of 12 months held to entitle petitioner to special relief from excess profits tax under Internal Revenue Code, section 721 (a) (2) (C), with adjustments for expenses deductible in computing net abnormal income, and after application of business improvement factor. W. B. Knight Machinery Co., 6 T. C. 519, followed. 2. Deductions for compensation to petitioner's officer-stockholders, held partly excessive. 3. Deductions for traveling expenses and sales commissions held to be…
1Opinion of the Court
Sommerfeld Machine Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Sommerfeld Machine Co. v. Commissioner
Docket No. 16040
United States Tax Court
15 T.C. 453; 1950 U.S. Tax Ct. LEXIS 68;
October 10, 1950, Promulgated
Decision will be entered under Rule 50.
1. Petitioner's receipt of income from manufacture and sale of lathes developed in prior years over a period in excess of 12 months held to entitle petitioner to special relief from excess profits tax under Internal Revenue Code, section 721 (a) (2) (C), with adjustments for expenses deductible in computing net abnormal…
Also in this document: Dissent.
2Cases cited7 opinions
- W. B. Knight Machinery Co. v. CommissionerUnited States Tax Court · 1946
- Soabar Co. v. CommissionerUnited States Tax Court · 1946
- Morrisdale Coal Mining Co. v. CommissionerUnited States Tax Court · 1949
- Keystone Brass Works v. CommissionerUnited States Tax Court · 1949
- Baltimore Foundry & Machine Corp. v. CommissionerUnited States Tax Court · 1946
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