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PLEASANT VALLEY WINE CO. v. COMMISSIONER

Docket No. 19394.

14 T.C. 519 (1950)

THE PLEASANT VALLEY WINE CO., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 31, 1950.

Attorney(s) appearing for the Case

Carl K. Goodson, Esq., for the petitioner.

R. P. Hertzog, Esq., for the respondent.

OPINION.

MURDOCK, Judge:

The petitioner filed an application for relief under section 722 with relation to its fiscal year ended August 31, 1944. The Commissioner held that it was not timely filed and disallowed it for that reason. The only issue for decision at this time is whether the application for relief was timely filed. The parties have filed a stipulation of facts.

Section 722 (d) provides that the benefits of that section shall not...

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