SOUTHLAND INDUSTRIES, INC. v. COMMISSIONER

Docket Nos. 24664, 25387, 25388, 25389.

17 T.C. 1551 (1952)

SOUTHLAND INDUSTRIES, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 21, 1952.


Attorney(s) appearing for the Case

Robert Ash, Esq., and Charles H. Burton, Esq., for the petitioner.

Roy A. Wentz, Esq., and Allen T. Akin, Esq., for the respondent.


The Commissioner disallowed petitioner's applications for relief under section 722 for the fiscal years ended July 31, 1941, through 1946.

The only question to be decided is whether the Commissioner erred in denying relief to the petitioner. The issues presented for decision are:

(1) Did petitioner change the character of its business within the meaning of section 722 (b) (4) by the installation of a vertical radiator-type antenna; and (2) is petitioner entitled...

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