Block One Thirty-Nine, Inc. v. Commissioner
United States Tax Court
Petitioner claimed relief for excess profits taxes under section 722 (c) (3) because its invested capital was abnormally low for each of the taxable years. Held, that where its proposed credit under the income method is smaller than the credits actually allowed under the invested capital method, it is not entitled to relief.
1Opinion of the Court
OPINION.
Black, Judge:
The only question presented in these proceedings is whether petitioner is entitled to. any relief from excess profits taxes under section 722 (c) (3) of the Internal Revenue Code for the fiscal years ended February 28,1943,1944, and 1945, and for the tax period from March 1, to December 31, 1945.
The applicable statute is printed in the margin.2
It will be noted that section 722 (c) provides three grounds for relief. Petitioner does not claim that section 722 (c) (1) and (2) have any application. .Petitioner claims that under section 722 (c) (3) its tax is excessive and…
2Cases cited11 opinions
- Lamar Creamery Co. v. CommissionerUnited States Tax Court · 1947
- Monarch Cap Screw & Mfg. Co. v. CommissionerUnited States Tax Court · 1945
- Blum Folding Paper Box Co. v. CommissionerUnited States Tax Court · 1945
- Danco Co. v. CommissionerUnited States Tax Court · 1950
- Irwin B. Schwabe Co. v. CommissionerUnited States Tax Court · 1949
6 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Springfield Tablet Mfg. Co. v. CommissionerUnited States Tax Court · 1954
- Midvale Co. v. CommissionerUnited States Tax Court · 1953
- Hugo Brand Tannery, Inc. v. CommissionerUnited States Tax Court · 1953
- Green Spring Dairy, Inc. v. CommissionerUnited States Tax Court · 1952
- Block One Thirty-Nine, Inc. v. CommissionerUnited States Tax Court · 1952
5 more not listed; retrieve them via the Exa API.