Hall Lithographing Co. v. Commissioner
United States Tax Court
Petitioner seeks relief under section 722 (a) and (b) (4), Internal Revenue Code of 1939, upon the ground that it changed the character of its business during the base period years because of (1) a change in management, and (2) the acquisition of the business of a competitor. Held, petitioner has failed to establish its right to relief under such section.
1Opinion of the Court
OPINION.
Mulroney, Judge:
Petitioner seeks relief under section 722 (a) and (b) (4), Internal Revenue Code of 1939. The pertinent provisions of the Code appear below.2 Sectional references are to the 1939 Code unless otherwise stated.
In determining its excess profits tax liability for the taxable years 1941-1945, inclusive, petitioner used the invested capital method to compute its excess profits credit. Under the invested capital method, petitioner’s excess profits credit for each taxable year ranged upward from $13,779.43 for 1941 to $19,883.12 for 1945. Such credits resulted in a lesser tax…
2Cases cited8 opinions
- Granite Constr. Co. v. CommissionerUnited States Tax Court · 1952
- Irwin B. Schwabe Co. v. CommissionerUnited States Tax Court · 1949
- Trunz, Inc. v. CommissionerUnited States Tax Court · 1950
- Toledo Stove & Range Co. v. CommissionerUnited States Tax Court · 1951
- General Metalware Co. v. CommissionerUnited States Tax Court · 1951
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3Cited by1 opinion
- Hall Lithographing Co. v. CommissionerUnited States Tax Court · 1956