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DOWD-FEDER, INC. v. COMMISSIONER

Docket No. 7793.

10 T.C. 345 (1948)

DOWD-FEDER, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 24, 1948.

Attorney(s) appearing for the Case

M. R. Schlesinger, Esq., for the petitioner.

Lawrence R. Bloomenthal, Esq., for the respondent.

OPINION.

VAN FOSSAN, Judge:

The respondent determined a deficiency of $7,885.51 in income tax and an overassessment of $6,552.18 in excess profits tax for the year 1941. Taxpayer alleges as error that:

1. In arriving at the excess profits credit for 1942 and resultant unused excess profits credit carry-back to 1941, the Commissioner erred in holding that the application of the so-called "75% rule" under Internal Revenue Code Section 713 (e...

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