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MILITARY v. COMMISSIONER

Docket Nos. 29701, 31608.

22 T.C. 721 (1954)

WENTWORTH MILITARY, SCIENTIFIC AND LITERARY EDUCATIONAL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 30, 1954.

Attorney(s) appearing for the Case

Elmer B. Hodges, Esq., for the petitioner.

David Karsted, Esq., for the respondent.

These consolidated proceedings involve claims for refund of excess profits taxes under section 722 for the fiscal years ended June 30, 1943, to June 30, 1946, inclusive. The respondent denied all applications. The issue is whether the petitioner is entitled to such relief by reason of an alleged change in management within the meaning of section 722 (b) (4) of the Internal Revenue Code.

FINDINGS OF FACT.

The stipulated...

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