Michael Schiavone & Sons, Inc. v. Commissioner
United States Tax Court
Excess Profits Tax -- Sec. 722 Relief -- Commencement of Business During Base Period. -- The petitioner, a dealer in scrap metals commenced business with adequate management and capacity 1 1/2 years after the beginning of its base period. Its sales had a direct relationship to the market price for scrap and the evidence does not establish that had it commenced business 2 years before it did so it would have had a higher level of earnings at the end of its base period.
1Opinion of the Court
Michael Schiavone & Sons, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Michael Schiavone & Sons, Inc. v. Commissioner
Docket No. 32222
United States Tax Court
27 T.C. 497; 1956 U.S. Tax Ct. LEXIS 17;
December 12, 1956, Filed
Decision will be entered for the respondent.
Excess Profits Tax -- Sec. 722 Relief -- Commencement of Business During Base Period. -- The petitioner, a dealer in scrap metals commenced business with adequate management and capacity 1 1/2 years after the beginning of its base period. Its sales had a direct relationship to the market price for scrap and the…
2Cases cited1 opinion
- Michael Schiavone & Sons, Inc. v. CommissionerUnited States Tax Court · 1956