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H. J. HEINZ CO. v. COMMISSIONER

Docket No. 44694.

32 T.C. 22 (1959)

H. J. HEINZ COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 10, 1959.

Attorney(s) appearing for the Case

Percy W. Phillips, Esq., for the petitioner.

Albert J. O'Connor, Esq., for the respondent.

OPINION.

TRAIN, Judge:

The Commissioner disallowed in part the petitioner's applications for relief under section 7221 for a number of its fiscal years including that ended April 30, 1943. In making his determination with respect to 1943, the Commissioner refused to allow an unused excess profits carryover from 1941 to 1943 in the amount of $42,881.72. The sole issue for our decision...

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