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Southeastern Canteen Co. And Canteen Service Co. Of Toledo, on Review v. Commissioner of Internal Revenue, on Review · 0 red 0 yellow 15 green 0 procedural Cited Wysong v. Commissioner Cited as authority Harmon City, Inc., a Utah Corporation v. United States Cited Milbrew, Inc. v. Commissioner of Internal Revenue Open case for full Syfertize analysis → 56
...The Commissioner’s disallowance of the surtax exemption is presumptively correct, and the burden of disproving such determination by a preponderance of the evidence is on petitioners. 26 C.F.R. § 1.269-5; Welch v. Helvering,