L. E. Carpenter & Co. v. Commissioner
United States Tax Court
Prior to 1941, the petitioner was a producer of book cloth, a chemically coated or impregnated fabric. In 1941 petitioner converted to the production of tent material for the Government. Held, under the record presented, the petitioner has not shown that any part of the income received from the production of tent material for the Government can be attributed to research and development in prior years within the meaning of section 721 (a) (2) (C), I. R. C. 1939.
1Opinion of the Court
L. E. Carpenter & Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
L. E. Carpenter & Co. v. Commissioner
Docket No. 54678
United States Tax Court
29 T.C. 562; 1957 U.S. Tax Ct. LEXIS 6;
December 30, 1957, Filed
Decision will be entered for the respondent.
Prior to 1941, the petitioner was a producer of book cloth, a chemically coated or impregnated fabric. In 1941 petitioner converted to the production of tent material for the Government. Held, under the record presented, the petitioner has not shown that any part of the income received from the production of tent material for…
2Cases cited2 opinions
- Pantasote Leather Co. v. CommissionerUnited States Tax Court · 1949
- L. E. Carpenter & Co. v. CommissionerUnited States Tax Court · 1957