Connecticut Light & Power Co. v. Commissioner
United States Tax Court
1. Sec. 722. -- Held, the respondent failed to establish error in his partial allowance of relief because of numerous affirmatively alleged contra-adjustments to the reconstruction. Held, further, that petitioner established (b)(4) base period changes in the character of the business consisting of a difference in capacity for production or operation entitling it to application of the 2-year pushback rule.
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1. Sec. 722. -- Held, the respondent failed to establish error in his partial allowance of relief because of numerous affirmatively alleged contra-adjustments to the reconstruction. Held, further, that petitioner established (b)(4) base period changes in the character of the business consisting of a difference in capacity for production or operation entitling it to application of the 2-year pushback rule. The amount of the CABPNI determined. 2. Sec. 722. -- Held, that petitioner is entitled to additional adjustment for base period abormality in interest and debt expense. 3. Sec. 722. -- Held,…
1Opinion of the Court
The Connecticut Light and Power Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Connecticut Light & Power Co. v. Commissioner
Docket No. 49321
United States Tax Court
40 T.C. 597; 1963 U.S. Tax Ct. LEXIS 92;
June 26, 1963, Filed
Decision will be entered under Rule 50.
1. Sec. 722. -- Held, the respondent failed to establish error in his partial allowance of relief because of numerous affirmatively alleged contra-adjustments to the reconstruction. Held, further, that petitioner established (b)(4) base period changes in the character of the business consisting of a difference in…
Also in this document: Dissent.
2Cases cited38 opinions
- Lewis v. ReynoldsSupreme Court of the United States · 1932
- Stone v. WhiteSupreme Court of the United States · 1937
- Bonwit Teller & Co. v. United StatesSupreme Court of the United States · 1931
- 7-Up Ft. Worth Co. v. CommissionerUnited States Tax Court · 1947
- Mutual Lumber Co. v. CommissionerUnited States Tax Court · 1951
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