Ajax Engineering Corporation v. Commissioner of Internal Revenue

Third Circuit

Ajax Engineering Corporation v. Commissioner of Internal Revenue

196 F.2d 727, 41 A.F.T.R. (P-H) 1235, 1952 U.S. App. LEXIS 4247

CourtCourt of Appeals for the Third Circuit

DecidedMay 15, 1952

Docket10635

StatusPublished

This text of 196 F.2d 727 (Ajax Engineering Corporation v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Ajax Engineering Corporation v. Commissioner of Internal Revenue, 196 F.2d 727, 41 A.F.T.R. (P-H) 1235, 1952 U.S. App. LEXIS 4247 (3d Cir. 1952).

Pincite

Opinion

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 *728 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.

I

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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 *728 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.

I

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Bluebook (online)

196 F.2d 727, 41 A.F.T.R. (P-H) 1235, 1952 U.S. App. LEXIS 4247, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ajax-engineering-corporation-v-commissioner-of-internal-revenue-ca3-1952.