TOLEDO ENGINEERING CO. v. COMMISSIONER

Docket No. 19520.

14 T.C. 765 (1950)

THE TOLEDO ENGINEERING CO., INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 5, 1950.


Attorney(s) appearing for the Case

Richard S. Cole, Esq., and A. J. Beran, C. P. A., for the petitioner.

John A. Newton, Esq., for the respondent.


This proceeding involves a claim for relief from excess profits tax for the calendar year 1943 in the amount of $55,502.93. Petitioner's application for relief was rejected by respondent in a notice dated June 8, 1948, which reads, in part, as follows:

It is held that you are not entitled to exclude any alleged abnormal income from your excess profits net income for 1943 under the provisions of section 721 of the Internal Revenue Code. Your claim for refund of excess...

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