Coe Laboratories, Inc. v. Commissioner
United States Tax Court
1. For many years, among other activities, petitioner has been engaged in the development and selling of dental impression materials. Beginning in February 1941 and continuing through the taxable years petitioner conducted research on an alginate impression material, the sales of which gave rise to income during the taxable years 1943 to 1946, inclusive.
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1. For many years, among other activities, petitioner has been engaged in the development and selling of dental impression materials. Beginning in February 1941 and continuing through the taxable years petitioner conducted research on an alginate impression material, the sales of which gave rise to income during the taxable years 1943 to 1946, inclusive. Held, petitioner has failed to prove that any portion of its income for the years 1943 to 1946, of the class described in section 721(a)(2)(C) of the Internal Revenue Code of 1939, as amended, was "net abnormal income" resulting from research…
1Opinion of the Court
TkaiN, Judge:
The petitioner claimed refunds and relief from excess profits taxes under sections 721 and 7221 as follows:
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The respondent denied the relief claimed, and determined deficiencies in income and excess profits taxes for the years and in the amounts as follows:
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Respondent further determined that petitioner was liable for an addition to tax in the amount of $112.15 under section 291 for failure to file a timely return for the year ended July 31, 1942, which determination petitioner concedes the correctness of. Both petitioner and respondent have conceded…
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