Pied Piper Shoe Co. v. Commissioner
United States Tax Court
The petitioner has been a manufacturer of infants', children's, misses', and growing girls' shoes since its incorporation in 1934 when it acquired the business of Marathon which had been producing such shoes in the high-quality, high-priced field since 1923. Petitioner claimed relief under section 722 of the Internal Revenue Code of 1939 from excess profits taxes for the fiscal years ended November 30, 1941 to 1946, inclusive, on the grounds that its level of earnings during…
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The petitioner has been a manufacturer of infants', children's, misses', and growing girls' shoes since its incorporation in 1934 when it acquired the business of Marathon which had been producing such shoes in the high-quality, high-priced field since 1923. Petitioner claimed relief under section 722 of the Internal Revenue Code of 1939 from excess profits taxes for the fiscal years ended November 30, 1941 to 1946, inclusive, on the grounds that its level of earnings during the base period was an inadequate standard of its normal earnings, largely because of economic circumstances resulting…
1Opinion of the Court
OPINION.
Kern, Judge:
In this proceeding the petitioner contests the respondent’s disallowance of its application for relief under section 722 of the Internal Revenue Code of 1939. Specifically, the petitioner invokes subparagraphs (b) (1), (b) (2), (b) (4), and (b) (5) of section 722.2
The petitioner’s claim for section 722 relief is based substantially on the following summary of facts: Petitioner’s predecessor corporation, hereinafter referred to as Marathon, was a manufacturer of high-quality and high-priced children’s and ladies’ shoes with certain outstanding features such as a patented…
2Cases cited5 opinions
- Granite Constr. Co. v. CommissionerUnited States Tax Court · 1952
- Toledo Stove & Range Co. v. CommissionerUnited States Tax Court · 1951
- Mitchell & Co. v. CommissionerUnited States Tax Court · 1953
- Sherman & Ellis, Inc. v. Indiana Mutual Casualty Co.Court of Appeals for the Seventh Circuit · 1930
- Hugo Brand Tannery, Inc. v. CommissionerUnited States Tax Court · 1953
3Cited by1 opinion
- Pied Piper Shoe Co. v. CommissionerUnited States Tax Court · 1957