PACIFIC METALS CORPORATION v. COMMISSIONER

Docket No. 109196.

1 T.C. 1028 (1943)

PACIFIC METALS CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 30, 1943.


Attorney(s) appearing for the Case

Richard W. Wilson, Esq., for the petitioner.

Walt Mandry, Esq., for the respondent.


OPINION.

HARRON, Judge:

The facts have been stipulated and the stipulation is adopted as our findings of fact. Petitioner, a New York corporation, filed its return for the year 1936 with the collector for the second district of New York.

The problem involves the application of section 131 of the Revenue Act of 1936, the pertinent parts of which are set forth in the margin.1

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