YUBA GARDENS, INC. v. COMMISSIONER

Docket Nos. 29189, 30329.

17 T.C. 334 (1951)

YUBA GARDENS, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 20, 1951.


Attorney(s) appearing for the Case

Bayley Kohlmeier, Esq., for the petitioner.

T. M. Mather, Esq., for the respondent.


The respondent has determined deficiencies in the petitioner's excess profits tax for the years 1942 and 1943 in the respective amounts of $52,361.77 and $28,242.18. The petitioner concedes that some of the adjustments made by the respondent are correct and contests only part of the deficiency in each year.

The question is whether the petitioner is entitled to attribute "net abnormal income" to years before and after the taxable years 1942 and 1943 under sections...

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