Harry Lang Mfg. Co. v. Commissioner
United States Tax Court
Petitioners were organized after December 31, 1939. During the taxable year they were engaged exclusively in the production of coveralls under Government contract for the armed forces.
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Petitioners were organized after December 31, 1939. During the taxable year they were engaged exclusively in the production of coveralls under Government contract for the armed forces. Petitioners filed claims for relief under section 722 (c) (1) and (3), I. R. C., for the taxable year ending June 30, 1944. Held, petitioners are not entitled to any relief under section 722 (c) because they have failed to establish a constructive average base period net income within the framework of section 722 (a).
1Opinion of the Court
opinion.
Harron, Judge:
The petitioners were organized after December 31, 1939, and they are, therefore, required by section 712 (a)4 of the I. R. C., to use the invested capital method in computing their credit for excess profits tax purposes. Petitioners seek relief under section 722 (c) (1) and (3) of the I. R. C.5 Petitioners allege, as qualifying factors, under section 722 (c) (1), the extensive experience, production skill, contacts and established reputation in the trade, of their common president and principal stockholder, Harry Lang. Petitioners contend they qualify under section 722…
2Cases cited1 opinion
- Danco Co. v. CommissionerUnited States Tax Court · 1950
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