Connecticut Light & Power Co. v. Commissioner
United States Tax Court
1. Sec. 722. -- Held, the respondent failed to establish error in his partial allowance of relief because of numerous affirmatively alleged contra-adjustments to the reconstruction. Held, further, that petitioner established (b)(4) base period changes in the character of the business consisting of a difference in capacity for production or operation entitling it to application of the 2-year pushback rule.
Read the full summary
1. Sec. 722. -- Held, the respondent failed to establish error in his partial allowance of relief because of numerous affirmatively alleged contra-adjustments to the reconstruction. Held, further, that petitioner established (b)(4) base period changes in the character of the business consisting of a difference in capacity for production or operation entitling it to application of the 2-year pushback rule. The amount of the CABPNI determined. 2. Sec. 722. -- Held, that petitioner is entitled to additional adjustment for base period abormality in interest and debt expense. 3. Sec. 722. -- Held,…
1Opinion of the Court
OPINION
Keen, Judge:
The respondent, in his statutory notice, partially disallowed petitioner’s applications for relief under section 722 of the Internal Revenue Code of 1939 and related claims for refund, and further partially allowed such application for relief. This partial allowance was based on respondent’s determination of petitioner’s qualification under sections 722(b) (1) and (b) (4) and a constructive average base period net income (cabpni) of $3,913,000 applicable to each of the years 1941 to 1945, inclusive, resulting in relief to petitioner over that available under section 713(f)…
Also in this document: Dissent.
2Cases cited33 opinions
- Lewis v. ReynoldsSupreme Court of the United States · 1932
- Bonwit Teller & Co. v. United StatesSupreme Court of the United States · 1931
- 7-Up Ft. Worth Co. v. CommissionerUnited States Tax Court · 1947
- Mutual Lumber Co. v. CommissionerUnited States Tax Court · 1951
- H. Fendrich, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1951
28 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Connecticut Light & Power Co. v. CommissionerUnited States Tax Court · 1963