DR. P. PHILLIPS CANNING CO. v. COMMISSIONER

Docket Nos. 7676, 27699.

17 T.C. 1222 (1952)

DR. P. PHILLIPS CANNING COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated January 24, 1952.


Attorney(s) appearing for the Case

George E. H. Goodner, Esq., and Dewey R. Roark, Jr., Esq., for the petitioner.

Roy A. Wentz, Esq., for the respondent.


The Commissioner denied applications for relief under section 722 for the fiscal years ended June 30, 1941, 1942, 1943, and 1944 and the only issue for decision is whether he erred in so doing.

FINDINGS OF FACT.

The petitioner was incorporated under the laws of Delaware on September 20, 1937, to engage in the business of canning citrus fruits. It kept its books and filed its returns on an accural basis and by fiscal years ending June 30. The petitioner took...

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