TRIANGLE RAINCOAT CO. v. COMMISSIONER

Docket No. 27317.

19 T.C. 548 (1952)

TRIANGLE RAINCOAT COMPANY, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 29, 1952.


Attorney(s) appearing for the Case

Benjamin Mahler, Esq., and Joseph Henry Cohen, Esq., for the petitioner.

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


Respondent rejected petitioner's application for relief from excess profits taxes under section 722 of the Internal Revenue Code with respect to the taxable years 1941, 1942, and 1943. Petitioner claims it is entitled to relief under section 722 (b) (1) and (b) (4). The basis for its claim under section 722 (b) (1) is a strike which occurred in its plant in 1936. Its claim under section 722 (b) (4) is based upon a change in the character of its business through (1) a difference...

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