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NORTHWEST CASUALTY COMPANY v. COMMISSIONER

Docket No. 37122.

29 T.C. 573 (1957)

NORTHWEST CASUALTY COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 30, 1957.

Attorney(s) appearing for the Case

Frederick J. Orth, Esq., and Hoyt M. Wilbanks, Jr., Esq., for the petitioner.

Aaron S. Resnick, Esq., for the respondent.

ATKINS, Judge:

The respondent disallowed in full the petitioner's claims for relief from excess profits tax under section 722 of the Internal Revenue Code of 1939 for the calendar years 1942 and 1943. The petitioner seeks a refund of $131,412.30 for the year 1942 and $150,866.18 for the year 1943, representing the entire amounts of excess profits taxes paid for those years.

The petitioner claims that its average...

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