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PRIMAS GROVES, INC. v. COMMISSIONER

Docket No. 17573.

15 T.C. 396 (1950)

PRIMAS GROVES, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 5, 1950.

Attorney(s) appearing for the Case

George E. H. Goodner, Esq., for the petitioner.

Irene Scott, Esq., and Newman A. Townsend, Jr., Esq., for the respondent.

This proceeding involves a claim for refund for excess profits tax under section 721 of the Internal Revenue Code for the fiscal year ended June 30, 1943.1 The amount of such tax, as paid by petitioner, for that year, was $12,772.39.

Broadly stated, the issue presented is whether petitioner is entitled to relief under section 721 (a) (2) (C) of the Code, because of its claim that it had abnormal income resulting from the development of...

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