Tober-Saifer Shoe Mfg. Co. v. Commissioner
United States Tax Court
Held, on the facts, that the petitioner has not shown a reconstruction of average base period net income in any amount larger than the figure allowed under section 713 (f), Internal Revenue Code, and is therefore not entitled to relief under section 722 (b) (4) because of change in character of business.
1Opinion of the Court
OPINION.
Disney, Judge:
The petitioner seeks relief from excess profits taxes under section 722 (b) (4) of the Internal Revenue Code. In its application for relief, filed with the Commissioner, petitioner contends that there were changes in the management of the business and in the character of the business and increases in the capacity for production. At the hearing and on brief petitioner narrows its position to merely a change in the character of the business. It contends that on January 1, 1936, it was an ordinary shoe jobber and that since that time, i. e., “By the end of 1937 the Jolene…
2Cases cited2 opinions
- East Texas Motor Freight Lines v. CommissionerUnited States Tax Court · 1946
- Singer Bros., Inc. v. CommissionerUnited States Tax Court · 1950
3Cited by8 opinions
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- Industrial Supplies, Inc. v. CommissionerUnited States Tax Court · 1952
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