PHILADELPHIA, GERMANTOWN AND NORRISTOWN RAILROAD COMPANY v. COMMISSIONER

Docket No. 7107.

6 T.C. 789 (1946)

PHILADELPHIA, GERMANTOWN AND NORRISTOWN RAILROAD COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 22, 1946.


Attorney(s) appearing for the Case

John E. McClure, Esq., for the petitioner.

Ralph A. Gilchrist, Esq., for the respondent.


The Commissioner disallowed petitioner's applications for relief under section 722 of the Internal Revenue Code and claims for refund of the excess profits taxes of $18,770.30 and $66,566.40 for 1941 and 1942, respectively, as shown by its returns and paid, for the reason that petitioner had not established (1) that the tax computed under subchapter E of chapter 2 of the Internal Revenue Code, without the benefit of section 722, resulted in an excessive and discriminatory...

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