AJAX ENGINEERING CORPORATION v. COMMISSIONER OF INTERNAL REVENUE

No. 10635.

196 F.2d 727 (1952)

AJAX ENGINEERING CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Third Circuit.

Decided May 15, 1952.


Attorney(s) appearing for the Case

Andrew B. Young, Philadelphia, Pa. (David P. Brown, Jr., Philadelphia, Pa., Frank W. Harris, Jr., Philadelphia, Pa., on the brief), for petitioner.

S. Dee Hanson, Washington, D. C. (Ellis N. Slack, Acting Asst. Atty. Gen., on the brief), for respondent.

Before MARIS, KALODNER and STALEY, Circuit Judges.


PER CURIAM.

Upon this petition to review a decision of the Tax Court the sole question is when the taxpayer's first taxable year began. The taxpayer was incorporated on February 7, 1942 and the Tax Court found that its first taxable year began on that date. 17 T.C. 87.

The taxpayer asserts that the court erred in this determination and that the evidence establishes that it commenced business as a de facto corporation prior to...

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