Wilson Athletic Goods Mfg. Co. v. Commissioner
United States Tax Court
1. Pleadings -- Cause of Action. -- A petition alleging facts to show that the taxpayer was not in existence for the full six years preceding the imposition of the processing tax and had inadequate records for that period and had requested unsuccessfully that the Commissioner use the average margin of representative concerns, but failing to allege any facts in regard to the tax period or any facts upon which relief could be based, does not set forth a cause of action. 2.…
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1. Pleadings -- Cause of Action. -- A petition alleging facts to show that the taxpayer was not in existence for the full six years preceding the imposition of the processing tax and had inadequate records for that period and had requested unsuccessfully that the Commissioner use the average margin of representative concerns, but failing to allege any facts in regard to the tax period or any facts upon which relief could be based, does not set forth a cause of action. 2. Unjust Enrichment Tax. -- Failure of Commissioner To Use Average Margin of Representative Concerns. -- Section 501 of the…
1Opinion of the Court
Wilson Athletic Goods Mfg. Co., Inc. (Formerly Wilson Sporting Goods Co.) (Formerly General Sports Inc.), Petitioner, v. Commissioner of Internal Revenue, Respondent
Wilson Athletic Goods Mfg. Co. v. Commissioner
Docket No. 123
United States Tax Court
2 T.C. 70; 1943 U.S. Tax Ct. LEXIS 147;
June 9, 1943, Promulgated
Decision will be entered for the respondent.
1. Pleadings -- Cause of Action. -- A petition alleging facts to show that the taxpayer was not in existence for the full six years preceding the imposition of the processing tax and had inadequate records for that period and had requested…
2Cases cited1 opinion
- Wilson Athletic Goods Mfg. Co. v. CommissionerUnited States Tax Court · 1943