Flotill Products, Inc. v. Commissioner
United States Tax Court
1. Flotill Products, Incorporated, Docket No. 31942. -- Constructive average base period net income determined under section 722 (b) (4), I. R. C. 1939. 2. Flotill Sales Corporation, Docket No. 32302. -- Petitioner held not qualified for relief under section 722 (c) where it was in existence prior to January 1, 1940.
1Opinion of the Court
OPINION.
Tietjens, Judge:
The first part of this Opinion will pertain to Flotill Products, Incorporated, Docket No. 31942. The term “petitioner” as herein used will refer to that company. Respondent determined that Flotill Products, Inc., qualifies for excess profits tax relief under section 722 (b) (4)—
by virtue of your incorporation during the base period (1939), coupled with a change in the character of the business continued by the new corporation, as evidenced by the change in management policies subsequent to acquisition of undivided control by the new ownership in 1939.
Respondent has…
2Cases cited1 opinion
- Eveready Loan Co. v. CommissionerUnited States Tax Court · 1943
3Cited by1 opinion
- Flotill Products, Inc. v. CommissionerUnited States Tax Court · 1956