Legal Opinion

Natatorium Laundry Co. v. Commissioner

United States Tax Court

Decided October 30, 1959No. Docket No. 32700Published

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

The Natatorium Laundry Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Natatorium Laundry Co. v. Commissioner

Docket No. 32700

United States Tax Court

33 T.C. 203; 1959 U.S. Tax Ct. LEXIS 51;

October 30, 1959, Filed

Decision will be entered for the respondent.

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,…

2Cases cited7 opinions

  1. Lamar Creamery Co. v. CommissionerUnited States Tax Court · 1947
  2. Harlan Bourbon & Wine Co. v. CommissionerUnited States Tax Court · 1950
  3. Midvale Co. v. CommissionerUnited States Tax Court · 1953
  4. Empire Constr. Co. v. CommissionerUnited States Tax Court · 1959
  5. Robertson Factories, Inc. v. CommissionerUnited States Tax Court · 1959

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