Simplicity Mfg. Co. v. Commissioner
United States Tax Court
Before 1937, petitioner produced cylinder-grinding machines which it sold to automobile repair shops. In 1937 it began making a new product, garden tractors, which it sold to Montgomery Ward. This constituted a change in the character of petitioner's business during the base period under section 722(b)(4). In its contract with Montgomery Ward it agreed to attempt to make improvements in the garden tractor.
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Before 1937, petitioner produced cylinder-grinding machines which it sold to automobile repair shops. In 1937 it began making a new product, garden tractors, which it sold to Montgomery Ward. This constituted a change in the character of petitioner's business during the base period under section 722(b)(4). In its contract with Montgomery Ward it agreed to attempt to make improvements in the garden tractor. In 1939, it produced a riding tractor, which was sold at a loss in 1939, and a new type of garden tractor with front attachments, which was sold in 1940. In 1940, petitioner also produced…
1Opinion of the Court
Simplicity Manufacturing Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Simplicity Mfg. Co. v. Commissioner
Docket No. 40765
United States Tax Court
34 T.C. 164; 1960 U.S. Tax Ct. LEXIS 157;
May 13, 1960, Filed
Decision will be entered for the respondent.
Before 1937, petitioner produced cylinder-grinding machines which it sold to automobile repair shops. In 1937 it began making a new product, garden tractors, which it sold to Montgomery Ward. This constituted a change in the character of petitioner's business during the base period under section 722(b)(4). In its contract with…
2Cases cited1 opinion
- Simplicity Mfg. Co. v. CommissionerUnited States Tax Court · 1960