H. Fendrich, Inc. v. Commissioner of Internal Revenue

DUFFY, Circuit Judge.

This is a petition for a review of a decision of the Tax Court. The question ta be decided is: In a petition for a review from a notice of disallowance of claims for relief under Sec. 722, Internal Revenue Code, 26 U.S.C. § 722, did the Tax Court correctly dismiss for want of jurisdiction the taxpayer’s petition in so far as it related to issues other than Sec. 722 relief?

Specifically the issue is whether the Tax Court has jurisdiction to determine the correct tax liability for excess profits tax under Sec. 732, Internal Revenue Code, 26 U.S.C. § 732, which section gives…