Pantasote Leather Co. v. Commissioner
United States Tax Court
Petitioner, a manufacturer of plastic-coated materials, engaged in research and development of particular processes and products, commencing in 1931, primarily to meet needs of the armed forces, derived a class of income falling within the purview of section 721 (a) (2) (C) of the code.
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Petitioner, a manufacturer of plastic-coated materials, engaged in research and development of particular processes and products, commencing in 1931, primarily to meet needs of the armed forces, derived a class of income falling within the purview of section 721 (a) (2) (C) of the code. Held, a portion of such income resulted from improvement in business, and the remainder is attributable to other years under section 721 (b), and is allocable to the years during which this research and development program was in operation.
1Opinion of the Court
OPINION.
Kern, Judge:
Section 721 of the Internal Revenue Code1 sought to provide relief to a taxpayer which received an abnormal amount or type of income in one year by permitting it to allocate such abnormal income over the years to which it was properly attributable,2 and thereby decrease the amount of excess profits tax to which it otherwise would have been subjected. The present controversy seems to us to be limited by respondent’s brief 3 to the narrow issue of whether or not all or some part of petitioner’s net abnormal income was properly attributable to years other than the ones in…
2Cases cited7 opinions
- Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
- Geyer, Cornell & Newell, Inc. v. CommissionerUnited States Tax Court · 1946
- W. B. Knight Machinery Co. v. CommissionerUnited States Tax Court · 1946
- Soabar Co. v. CommissionerUnited States Tax Court · 1946
- Ramsey Accessories Mfg. Corp. v. CommissionerUnited States Tax Court · 1948
2 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Steel or Bronze Piston Ring Corp. v. CommissionerUnited States Tax Court · 1949
- Primas Groves, Inc. v. CommissionerUnited States Tax Court · 1950
- Ohio Machine Tool Co. v. CommissionerUnited States Tax Court · 1952
- Sprague Electric Co. v. CommissionerUnited States Tax Court · 1961
- Breeze Corps. v. CommissionerUnited States Tax Court · 1951
12 more not listed; retrieve them via the Exa API.