Sno-Frost, Inc. v. Commissioner
United States Tax Court
Snow Crop, a processor and packager of frozen foods, distributed them for sale partly through franchised distributors on a nationwide basis. In 1949 Snow Crop announced a company policy to the effect that thereafter franchises would be granted to distributors who, in case they were in a different line of business, would agree to establish a separate business entity to operate under a Snow Crop franchise.
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Snow Crop, a processor and packager of frozen foods, distributed them for sale partly through franchised distributors on a nationwide basis. In 1949 Snow Crop announced a company policy to the effect that thereafter franchises would be granted to distributors who, in case they were in a different line of business, would agree to establish a separate business entity to operate under a Snow Crop franchise. Preliminary to the cancellation of the franchise of its then distributor for certain areas in Ohio, who was in financial difficulties, Snow Crop in the latter part of 1950 negotiated with…
1Opinion of the Court
Withey, Judge:
Deficiencies in income tax for 1953 and 1954 have been determined by respondent against petitioner in the respective amounts of $9,688.81 and $5,500. The issue presented by the pleadings is whether the respondent has erred in disallowing for 1953 a surtax exemption and a minimum excess profits credit to petitioner under section 15 (c) of the Internal Eevenue Code of 1939 and in disallowing for 1954 a surtax exemption and an accumulated earnings credit under section 1551 of the Internal Eevenue Code of 1954.
FINDINGS OF FACT.
The facts which have been stipulated are so found.
Petitio…
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