Dayton Rubber Co. v. Commissioner
United States Tax Court
Petitioner was incorporated in 1905. For many years prior to its base period (fiscal years ended October 31, 1937, to October 31, 1940, inclusive) it manufactured tires and tubes, belts, rollers, and miscellaneous products under separate divisions. In 1938, it set up a new textile division. During the remainder of its base period it had an over-all net loss from textile.
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Petitioner was incorporated in 1905. For many years prior to its base period (fiscal years ended October 31, 1937, to October 31, 1940, inclusive) it manufactured tires and tubes, belts, rollers, and miscellaneous products under separate divisions. In 1938, it set up a new textile division. During the remainder of its base period it had an over-all net loss from textile. Its old business income for the last 2 years of its base period was greatly in excess of its income for the first 2 years. Parties agree that setting up textile was a change in the character of petitioner's business under…
1Opinion of the Court
The Dayton Rubber Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Dayton Rubber Co. v. Commissioner
Docket Nos. 47294, 53682
United States Tax Court
26 T.C. 389; 1956 U.S. Tax Ct. LEXIS 177;
May 31, 1956, Filed
Decisions will be entered for the respondent.
Petitioner was incorporated in 1905. For many years prior to its base period (fiscal years ended October 31, 1937, to October 31, 1940, inclusive) it manufactured tires and tubes, belts, rollers, and miscellaneous products under separate divisions. In 1938, it set up a new textile division. During the remainder of its base…
2Cases cited7 opinions
- Homer Laughlin China Co. v. CommissionerUnited States Tax Court · 1946
- Stimson Mill Co. v. CommissionerUnited States Tax Court · 1946
- Stimson Mill Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1947
- Dowd-Feder, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
- Dowd-Feder, Inc. v. CommissionerUnited States Tax Court · 1948
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