United States Tax Court January 31, 1958, Docket No. 29689 (Royal Cotton Mill Co. v. Commissioner)

lead-opinion

OPINION.

Black, Judge:

The issues will be discussed in the same order as the findings of fact relating to them.

Issue 1. Section 722 Belief.

Petitioner seeks excess profits tax relief, relying on section 722 (a) and (b) (4). The first question is whether the petitioner has established the existence of a qualifying factor.