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UNI-TERM STEVEDORING CO., INC. v. COMMISSIONER

Docket No. 1465.

3 T.C. 917 (1944)

UNI-TERM STEVEDORING CO., INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 29, 1944.

Attorney(s) appearing for the Case

Milton J. Levitt, Esq., for the petitioner.

Mason B. Leming, Esq., and J. D. Bierman, Esq., for the respondent.

Before MURDOCK and DISNEY, Judges.

OPINION.

MURDOCK, Judge:

The parties have raised and argued a jurisdictional question on the petitioner's motion for leave to file an amended petition. The question which they have argued is, Has this Court jurisdiction to consider and rule upon an application by the petitioner for relief under section 722 of the Internal Revenue Code in this proceeding, which is based entirely upon a notice of deficiency in excess profits taxes for 1940?

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