Daniels Buick, Inc. v. Commissioner of Internal Revenue

This is a petition to review a determination of the tax court that the petitioner, Daniels Buick, Inc., was not a “purchasing corporation” within the meaning of Section 474(a) of the Internal Revenue Code of 1939, 26 U.S.C.A. Excess Profits Taxes, § 474(a), since it did not purchase substantially all the properties (other than cash) of another corporation, and therefore was not entitled to use the base period (1946 to 1949 inclusive) experience of such predecessor corporation in computing its excess profits credit for the year 1951. 26 T.C. 894.

A summary of the pertinent facts as found by the…