Metallurgical, Inc. v. The Renegotiation Board

FLOYD R. GIBSON, Circuit Judge.

Petitioner, Metallurgical, Inc., seeks review under § 7482 Internal Revenue Code. 26 U.S.C. § 7482(a), of a decision of the Tax Court determining excessive profits of $110,000.00 against the petitioner on renegotiable business for petitioner’s 1954 fiscal year. Petitioner is a Minnesota corporation engaged in the business of heat treating of metals.

The issues in the Tax Court, which has authority to hear these types of cases de novo, were by stipulation limited to (1) whether petitioner filed a timely application with the Renegotiation Board for a standard…