Jackson-Raymond Co. v. Commissioner
United States Tax Court
Excess profits tax relief under section 722 (c) of the Internal Revenue Code of 1939 disallowed where the petitioner in 1941 began the manufacture of uniform shirts and slacks, principally for military use, and where the evidence fails to establish a basis for reconstruction of normal base period earnings productive of greater excess profits credits than those allowed by the respondent on the invested capital basis.
1Opinion of the Court
OPINION.
Bettce, Judge:
It is petitioner’s contention that intangible assets which were not includible in invested capital made important contributions to its income; that its invested capital was abnormally low; and that its excess profits credits, based on invested capital, result in an excessive and discriminatory tax for each of the years involved.
We have found as a fact that the services of petitioner’s three organizers and principal officers were important factors in the success of its business. We may assume that this fact qualifies the petitioner for relief under section 722 (c) (1) of…
2Cases cited4 opinions
- Danco Co. v. CommissionerUnited States Tax Court · 1950
- Fezandie & Sperrle v. Comm'rUnited States Tax Court · 1945
- Danco Co. v. CommissionerUnited States Tax Court · 1952
- Harry Lang Mfg. Co. v. CommissionerUnited States Tax Court · 1952
3Cited by1 opinion
- Jackson-Raymond Co. v. CommissionerUnited States Tax Court · 1955