STOW MANUFACTURING CO. v. COMMISSIONER

Docket No. 19923.

14 T.C. 1440 (1950)

STOW MANUFACTURING COMPANY, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 30, 1950.


Attorney(s) appearing for the Case

George C. Coughlin, Esq., and Carbery O'Shea, Esq., for the petitioner.

Ellyne E. Strickland, Esq., for the respondent.


In this proceeding respondent has determined a deficiency in excess profits tax for the calendar year 1942 in the amount of $27,436.69. Petitioner claims that it has overpaid its excess profits tax for 1942 by $563.31.

The question which we have here to decide may be stated thus: Can respondent properly determine a deficiency by a computation method in which he excludes from petitioner's excess profits net income the amount of excessive profits determined in renegotiation...

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