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WILLYS-OVERLAND MOTORS v. COMMISSIONER OF INT. REV.

No. 12217.

219 F.2d 251 (1955)

WILLYS-OVERLAND MOTORS, Inc., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Sixth Circuit.

February 23, 1955.

Attorney(s) appearing for the Case

Milton C. Boesel, Ritter, Boesel & Lord, Toledo, Ohio, on the brief, for petitioner.

H. Brian Holland, Ellis N. Slack, Lee A. Jackson, Harry Marselli, Washington, D. C., for respondent.

Before ALLEN, MILLER and STEWART, Circuit Judges.

PER CURIAM.

Following the disallowance by the Commissioner of Internal Revenue of claims filed by the taxpayer, Willys-Overland Motors, Inc., for relief under Sec. 722, Internal Revenue Code, 26 U.S. C.A. § 722, due to abnormalities in the base period income, with respect to excess profits taxes for its taxable years ended September 30, 1942, 1943, 1944 and 1945, the taxpayer, on April 21, 1950, filed its petition in the Tax Court challenging the disallowance...

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