PIONEER PARACHUTE COMPANY, INC. v. COMMISSIONER

Docket No. 3367.

6 T.C. 1246 (1946)

PIONEER PARACHUTE COMPANY, INC., v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 31, 1946.


Attorney(s) appearing for the Case

Edmund S. Kochersperger, Esq., for the petitioner.

Charles P. Reilly, Esq., for the respondent.


The Commissioner determined a deficiency in excess profits tax in the amount of $45,162.66 for the calendar year 1941. Petitioner contests this determination and claims it is entitled to a refund of excess profits tax in the amount of $1,983.97.

The question presented is whether petitioner and Cheney Brothers constituted an "affiliated group" as defined in section 730 (d) of the Internal Revenue Code during the period March 30 to December 31, 1941, and, as such, were...

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