Packer Publishing Co. v. Commissioner
United States Tax Court
1. Evidence showing long term downward trend in profits of petitioner's newspaper business, rather than variant profit cycle or temporary or unusual economic circumstances, held not to entitle it to relief under sections 722 (b) (3) (A), or 722 (b) (2). 2. Change of contracts during base period which materially altered manner of operation of petitioner's comic supplement business held to entitle it to relief under section 722 (b) (4) as a change in the character of the…
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1. Evidence showing long term downward trend in profits of petitioner's newspaper business, rather than variant profit cycle or temporary or unusual economic circumstances, held not to entitle it to relief under sections 722 (b) (3) (A), or 722 (b) (2). 2. Change of contracts during base period which materially altered manner of operation of petitioner's comic supplement business held to entitle it to relief under section 722 (b) (4) as a change in the character of the business. 3. Unused excess profits tax credit carry-over based on special relief and shown in computation of claims for…
1Opinion of the Court
Packer Publishing Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Packer Publishing Co. v. Commissioner
Docket No. 26369
United States Tax Court
17 T.C. 882; 1951 U.S. Tax Ct. LEXIS 30;
November 28, 1951, Promulgated
Decision will be entered under Rule 50.
1. Evidence showing long term downward trend in profits of petitioner's newspaper business, rather than variant profit cycle or temporary or unusual economic circumstances, held not to entitle it to relief under sections 722 (b) (3) (A), or 722 (b) (2).
2. Change of contracts during base period which materially altered manner…
2Cases cited12 opinions
- Monarch Cap Screw & Mfg. Co. v. CommissionerUnited States Tax Court · 1945
- Wisconsin Farmer Co. v. CommissionerUnited States Tax Court · 1950
- Mutual Lumber Co. v. CommissionerUnited States Tax Court · 1951
- Great Atlantic & Pacific Tea Co. v. Federal Trade CommissionCourt of Appeals for the Third Circuit · 1939
- Harlan Bourbon & Wine Co. v. CommissionerUnited States Tax Court · 1950
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