United Mail Order House v. Commissioner
United States Tax Court
Claims for excess profits tax relief under section 722 (b) (4), I. R. C. 1939, disallowed where evidence fails to show any substantial qualifying changes in the character of the business or any sound basis for a reconstruction of base period earnings.
1Opinion of the Court
OPINION.
Aeundell, Judge:
Petitioner contends that its average base period net income is an inadequate standard of normal earnings because of certain base period changes in the character of its business within the purview of section 722 (b) (4), Internal Revenue Code of 1939. These alleged changes consist of (1) moving its offices to a larger, new location, (2) acquiring new clients through contracts with former competitors, and (3) changing and enlarging its operations by providing new types of service for its clients.
Petitioner moved its offices from 1071 Sixth Avenue, New York City, to 225…
2Cases cited5 opinions
- Wisconsin Farmer Co. v. CommissionerUnited States Tax Court · 1950
- Avey Drilling Machine Co. v. CommissionerUnited States Tax Court · 1951
- Granite Constr. Co. v. CommissionerUnited States Tax Court · 1952
- Toledo Stove & Range Co. v. CommissionerUnited States Tax Court · 1951
- Godfrey Food Co. v. CommissionerUnited States Tax Court · 1952
3Cited by3 opinions
- Schenley Industries, Inc. v. CommissionerUnited States Tax Court · 1964
- Schenley Industries, Inc. v. CommissionerUnited States Tax Court · 1964
- United Mail Order House v. CommissionerUnited States Tax Court · 1956