Brown Paper Mill Co. v. Commissioner
United States Tax Court
1. Petitioner's claim for relief under section 722 (b) (2)held properly disallowed for failure to establish that any decline in its earnings or those of any industry of which it was a part during the base period was due to any temporary or unusual economic events or circumstances. 2. Petitioner's claim for relief under section 722 (b) (4) on the ground that installation of refining machinery increased its capacity to produce during the base period held not established by the…
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1. Petitioner's claim for relief under section 722 (b) (2)held properly disallowed for failure to establish that any decline in its earnings or those of any industry of which it was a part during the base period was due to any temporary or unusual economic events or circumstances. 2. Petitioner's claim for relief under section 722 (b) (4) on the ground that installation of refining machinery increased its capacity to produce during the base period held not established by the evidence. 3. Petitioner's claim for relief under section 722 (b) (4) on the ground that installation of dehydrating…
1Opinion of the Court
OPINION.
OppeR, Judge:
Respondent determined deficiencies in petitioner’s income and excess profits taxes and disallowed claims for relief under section 722 of the Internal Revenue Code of 1939 as follows:
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Petitioner also claims overpayments of income tax for the years 1942 through 1945, inclusive. Certain issues have been settled by stipulation; other adjustments are conceded by petitioner. The remaining questions are:
1. Whether petitioner is qualified for excess profits tax relief for all years in controversy because its average net income during the base period 1936 through 1939…
2Cases cited30 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- Angelus Milling Co. v. CommissionerSupreme Court of the United States · 1945
- Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943
25 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Crowell-Collier Pub. Co. v. CommissionerUnited States Tax Court · 1956
- The Brown Paper Mill Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
- Overland Corp. v. CommissionerUnited States Tax Court · 1960
- Bergstrom Paper Co. v. CommissionerUnited States Tax Court · 1956
- Blue Diamond Coal Co. v. CommissionerUnited States Tax Court · 1959
25 more not listed; retrieve them via the Exa API.