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  • Ajax Engineering Corporation v. Commissioner of Internal Revenue, 196 F.2d 727, 3rd Cir. (1952)

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    The document is a court case summary that addresses when a taxpayer's first taxable year began. The Tax Court found the taxpayer's first taxable year began on February 7, 1942, the date it was incorporated. The taxpayer asserted it began business as a de facto corporation before December 31, 1941. The appellate court affirmed the Tax Court's decision, finding the evidence supported the Tax Court's factual determination of the first taxable year beginning date.

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    Filed: 1952-05-15 Precedential Status: Precedential Citations: 196 F.2d 727 Docket: 10635

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    The document is a court case summary that addresses when a taxpayer's first taxable year began. The Tax Court found the taxpayer's first taxable year began on February 7, 1942, the date it was incorporated. The taxpayer asserted it began business as a de facto corporation before December 31, 1941. The appellate court affirmed the Tax Court's decision, finding the evidence supported the Tax Court's factual determination of the first taxable year beginning date.

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    6 views2 pages

    Ajax Engineering Corporation v. Commissioner of Internal Revenue, 196 F.2d 727, 3rd Cir. (1952)

    Uploaded by

    Scribd Government Docs
    The document is a court case summary that addresses when a taxpayer's first taxable year began. The Tax Court found the taxpayer's first taxable year began on February 7, 1942, the date it was incorporated. The taxpayer asserted it began business as a de facto corporation before December 31, 1941. The appellate court affirmed the Tax Court's decision, finding the evidence supported the Tax Court's factual determination of the first taxable year beginning date.

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    of 2

    196 F.

    2d 727

    AJAX ENGINEERING CORPORATION, Petitioner


    v.
    COMMISSIONER OF INTERNAL REVENUE, Respondent.
    No. 10635.

    United States Court of Appeals Third Circuit.


    Argued April 22, 1952.
    Decided May 15, 1952.

    Petition for Review of the Decision of the Tax Court of the United States.
    Andrew B. Young, Philadelphia, Pa. (David P. Brown, Jr., Philadelphia,
    Pa., Frank W. Harris, Jr., Philadelphia, Pa., on the brief), for petitioner.
    S. Dee Hanson, Washington, D. C. (Ellis N. Slack, Acting Asst. Atty.
    Gen., on the brief), for respondent.
    Before MARIS, KALODNER and STALEY, Circuit Judges.
    PER CURIAM.

    Upon this petition to review a decision of the Tax Court the sole question is
    when the taxpayer's first taxable year began. The taxpayer was incorporated on
    February 7, 1942 and the Tax Court found that its first taxable year began on
    that date. 17 T.C. 87.

    The taxpayer asserts that the court erred in this determination and that the
    evidence establishes that it commenced business as a de facto corporation prior
    to December 31, 1941.

    It will be observed that the question thus raised is a purely factual one which
    the Tax Court upon consideration of the evidence has resolved against the
    taxpayer's contention. Our examination of the record satisfies us that the
    evidence supports the conclusion of the Tax Court in this regard. Accordingly
    we cannot say that it is erroneous.

    The decision of the Tax Court will be affirmed.

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