Lily Mills Co. v. Commissioner
United States Tax Court
The petitioner challenged as inadequate the relief accorded to it by the Commissioner by reason of certain changes in the character of its business which qualified it for relief under section 722 (b) (4) of the Internal Revenue Code. Constructive average base period net income determined.
1Opinion of the Court
OPINION.
Hill, Judge:
The principal question in issue here is whether the petitioner is entitled under the provisions of section 722 (b) (4)1 to a greater average base period net income and consequently a greater excess profits credit for the years involved than that allowed by the respondent.
The petitioner contends, and the respondent agrees, that the petitioner is entitled to relief under section 722 (b) (4) by reason of the changes in character of its business brought about by the introduction of Article No. 241, a new product, and the establishment of three branch warehouses for the…
2Cases cited1 opinion
- Superior Valve & Fittings Co. v. CommissionerUnited States Tax Court · 1952
3Cited by2 opinions
- The Crowell-Collier Publishing Company v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1958
- Lily Mills Co. v. CommissionerUnited States Tax Court · 1954