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GROGAN MANUFACTURING CO. v. COMMISSIONER

Docket No. 29050.

22 T.C. 161 (1954)

GROGAN MANUFACTURING COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 28, 1954.

Attorney(s) appearing for the Case

John A. Osoinach, Esq., for the petitioner.

Allen T. Akin, Esq., for the respondent.

The respondent has disallowed claims for refund of $3,051.58 and $4,592.82 in excess profits taxes paid by petitioner for the taxable years 1941 and 1942. The question presented is whether or not petitioner, in each of the taxable years, had abnormal income within the meaning of section 721 (a) (2) (C) of the Internal Revenue Code, "resulting from * * * development of tangible property * * * extending over a period of more than 12...

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