Lansburgh & Bro. v. Commissioner
United States Tax Court
Sec. 722 (b) (4) -- Change in Character of Business. -- Held: Petitioner qualifies for relief. Determination made of a fair and just amount representing normal earnings to be used as petitioner's constructive average base period net income for the taxable years ended January 31, 1941 through 1946.
1Opinion of the Court
OPINION.
Aeundell, Judge:
The respondent denied petitioner’s applications for excess profits tax relief under section 722 of the Internal Revenue Code of 1939, and related claims for refund for the taxable years ended January 31,1941 to 1946, both inclusive.
The questions presented for decision are whether petitioner is qualified for relief under section 722 (b) (4) by reason of several alleged changes in the character of the business during the base period, and also alleged changes in capacity for production or operation consummated after December 31,1939, as a result of a course of action to…
2Cases cited3 opinions
- Springfield Tablet Mfg. Co. v. CommissionerUnited States Tax Court · 1954
- Crowell-Collier Pub. Co. v. CommissionerUnited States Tax Court · 1956
- Peter J. Schweitzer, Inc. v. CommissionerUnited States Tax Court · 1958
3Cited by8 opinions
- Stanton v. CommissionerUnited States Tax Court · 1960
- Copco Steel & Engineering Co. v. CommissionerUnited States Tax Court · 1958
- Simplicity Mfg. Co. v. CommissionerUnited States Tax Court · 1960
- Connecticut Light & Power Co. v. CommissionerUnited States Tax Court · 1963
- Connecticut Light & Power Co. v. CommissionerUnited States Tax Court · 1963
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