JOHN KELLEY CO. v. COMMISSIONER

Docket No. 109088.

1 T.C. 457 (1943)

JOHN KELLEY COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated January 15, 1943.


Attorney(s) appearing for the Case

Frank J. Albus, Esq., for the petitioner.

John D. Kiley, Esq., for the respondent.


The respondent has determined against petitioner income tax deficiencies for the calendar years 1937, 1938, and 1939 in the amounts of $569.06, $1,980, and $1,980, respectively, and an excess profits tax deficiency in the amount of $360 for 1937.

The only issue presented is whether the payments on corporate debentures were interest on indebtedness or dividends on stock.

FINDINGS OF FACT.

Substantially all the facts are stipulated and are hereby found...

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