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A. FINKL & SONS CO. v. COMMISSIONER

Docket No. 44728.

38 T.C. 886 (1962)

A. FINKL & SONS COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 19, 1962.

Attorney(s) appearing for the Case

Carl J. Batter, Esq., for the petitioner.

John W. Holt, Esq., for the respondent.

FORRESTER, Judge:

Respondent has denied petitioner's application for relief under section 7221 for the year 1944 in the amount of $844,206.73. The issues presented for our determination are: (1) Whether petitioner's plant rehabilitation and modernization program was an event "unusual in the experience of the taxpayer" within the meaning of section 722(b)(1) or increased petitioner's "capacity...

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