Fezandie & Sperrle v. Comm'r
United States Tax Court
Change in character of business which could not have been made but for the occurrence of the European War, held not to entitle petitioner to relief under section 722.
1Opinion of the Court
OPINION.
Oppek, Judge:
Dealing with the reconstructed base period of section 722 for excess profits tax purposes brings to mind Mr. Churchill’s reference, in a different context, to a “riddle inside a mystery wrapped in an enigma.” Procedure under that section seems to call for founding hypothesis on assumption based on supposition. The present question reduces to how far we may properly go in presupposing the existence of admittedly imaginary circumstances.
The change in its business upon which petitioner premises its application actually took place at the very close of the base period. At that…
2Cited by30 opinions
- Wisconsin Farmer Co. v. CommissionerUnited States Tax Court · 1950
- Ainsworth Mfg. Corp. v. CommissionerUnited States Tax Court · 1954
- Midvale Co. v. CommissionerUnited States Tax Court · 1953
- Ciba Pharmaceutical Products, Inc. v. CommissionerUnited States Tax Court · 1960
- Columbia Broadcasting System, Inc. v. CommissionerUnited States Tax Court · 1959
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