Springfield Tablet Mfg. Co. v. Commissioner
United States Tax Court
Petitioner's average base period net income increased over the amount determined by respondent in his partial allowance of petitioner's applications for relief under section 722 (b) (4), Internal Revenue Code, by reason of a change in the character of its business to which petitioner was committed prior to January 1, 1940. The change consisted of the addition of an envelope and writing paper manufacturing department to petitioner's regular business of manufacturing tablets…
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Petitioner's average base period net income increased over the amount determined by respondent in his partial allowance of petitioner's applications for relief under section 722 (b) (4), Internal Revenue Code, by reason of a change in the character of its business to which petitioner was committed prior to January 1, 1940. The change consisted of the addition of an envelope and writing paper manufacturing department to petitioner's regular business of manufacturing tablets and school supplies.
1Opinion of the Court
OPINION.
ARijndell, Judge:
Respondent has recognized petitioner’s qualification for relief under section 722 (b) (4), by reason of its commitment prior to January 1, 1940, to a course of action constituting a change in the character of its business, and has made a partial allowance of petitioner’s claims. In such partial allowance the respondent used a constructive average base period net income of $41,300 for the taxable years 1942 to 1946, inclusive, whereas petitioner contends that it is entitled to a constructive average base period net income of $64,860.30. Its actual average base period…
2Cases cited5 opinions
- Blum Folding Paper Box Co. v. CommissionerUnited States Tax Court · 1945
- Wisconsin Farmer Co. v. CommissionerUnited States Tax Court · 1950
- Trunz, Inc. v. CommissionerUnited States Tax Court · 1950
- Wadley Co. v. CommissionerUnited States Tax Court · 1951
- Block One Thirty-Nine, Inc. v. CommissionerUnited States Tax Court · 1952
3Cited by21 opinions
- Crowell-Collier Pub. Co. v. CommissionerUnited States Tax Court · 1956
- The Crowell-Collier Publishing Company v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1958
- Lansburgh & Bro. v. CommissionerUnited States Tax Court · 1958
- Peter J. Schweitzer, Inc. v. CommissionerUnited States Tax Court · 1958
- Copco Steel & Engineering Co. v. CommissionerUnited States Tax Court · 1958
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