Detroit Macoid Corp. v. Commissioner

OPINION.

Van Fossan, Judge:

In the opinion reported at 23 T. C. 382, we concluded that petitioner had not demonstrated that it was entitled to a greater credit than that allowed by respondent. On reconsideration we now conclude that petitioner has established its right to a larger constructive average base period net income.

In acting upon petitioner’s claims for refund, respondent concluded that petitioner’s extruded plastic strip constituted a new product which was profitable to the petitioner, and determined that petitioner was entitled to a constructive average base period net income of…