Natatorium Laundry Co. v. Commissioner
United States Tax Court
1. Petitioner having failed to show any relation between claimed section 722(b)(1) and (5), I.R.C. 1939, factors and base period earnings, relief is denied. 2. Claimed section 722(b)(2), I.R.C. 1939, relief denied on failure of proof. 3. Even assuming that petitioner has established a section 722(b)(4), I.R.C. 1939, factor, yet its CABPNI based on this section is not in excess of that already allowed under section 713(e), and hence petitioner is entitled to no section…
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1. Petitioner having failed to show any relation between claimed section 722(b)(1) and (5), I.R.C. 1939, factors and base period earnings, relief is denied. 2. Claimed section 722(b)(2), I.R.C. 1939, relief denied on failure of proof. 3. Even assuming that petitioner has established a section 722(b)(4), I.R.C. 1939, factor, yet its CABPNI based on this section is not in excess of that already allowed under section 713(e), and hence petitioner is entitled to no section 722(b)(4) relief.
1Opinion of the Court
Forrester, Judge:
Petitioner challenges respondent’s disallowance of its claim for relief under section 122 of the Internal Revenue Code of 1939 for the taxable years 1944 and 1945. The taxable years 1942 and 1943 are also involved by reason of claimed carryover credits.
FINDINGS OF FACT.
Some of the facts have been stipulated and are so found.
The petitioner is a corporation organized under the laws of the State of Texas, with its principal place of business in Fort Worth. Its Federal income and excess profits tax returns, for each of the calendar years 1942,1943,1944, and 1945, were filed on an…
2Cases cited6 opinions
- Lamar Creamery Co. v. CommissionerUnited States Tax Court · 1947
- Harlan Bourbon & Wine Co. v. CommissionerUnited States Tax Court · 1950
- Midvale Co. v. CommissionerUnited States Tax Court · 1953
- Empire Constr. Co. v. CommissionerUnited States Tax Court · 1959
- Robertson Factories, Inc. v. CommissionerUnited States Tax Court · 1959
1 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- A. Finkl & Sons Co. v. CommissionerUnited States Tax Court · 1962
- A. Finkl & Sons Co. v. CommissionerUnited States Tax Court · 1962
- Natatorium Laundry Co. v. CommissionerUnited States Tax Court · 1959