MICHAEL SCHIAVONE & SONS, INC. v. COMMISSIONER

Docket No. 32222.

27 T.C. 497 (1956)

MICHAEL SCHIAVONE & SONS, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 12, 1956.


Attorney(s) appearing for the Case

Raymond F. Garrity, Esq., and Carl A. Phillipps, Esq., for the petitioner.

William V. Crosswhite, Esq., for the respondent.


OPINION.

MURDOCK, Judge:

The Commissioner has disallowed the petitioner's claims for excess profits tax relief under section 722 (b) (4) for each of the fiscal years ended February 28, 1941 through 1945. The evidence was heard by a commissioner of this Court and his proposed findings of fact have been served upon the parties. The petitioner did not file any proposed findings of fact as required by Rule 48 of the Rules of Practice of the Tax Court...

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