Crossfield Prods. Corp. v. Comm'r of Internal Revenue

1 Citing case

  1. Smith's Heating, Inc. v. Comm'r of Internal Revenue

    24 T.C. 533 (U.S.T.C. 1955)   Cited 1 times

    The record establishes, and we have so found, that the petitioner's invested capital was abnormally low within the meaning of section 722(c)(3). Where a taxpayer qualifies under any one of the three conditions set forth in (1), (2), and (3) of section 722(c), it is entitled to receive consideration of its claim for relief. Crossfield Products Corporation, 20 T.C. 97; Tin Processing Corporation, 16 T.C. 713, 722; Regs. 112, sec. 35.722-4. The question to be decided is whether petitioner is entitled to an amount for constructive average base period net income which would result in a credit in excess of the amount computed by the invested capital method and allowed by the respondent.