FIFTH AVENUE-14TH STREET CORPORATION v. COMMISSIONER

Docket No. 108789.

2 T.C. 516 (1943)

FIFTH AVENUE-14TH STREET CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated August 6, 1943.


Attorney(s) appearing for the Case

Harry Friedman, Esq., for the petitioner.

Conway Kitchen, Esq., for the respondent.


This proceeding involves the redetermination of the following deficiencies in income tax:

1935 ----------------------------------------   $1,105.92
1936 ----------------------------------------    2,669.40
1937 ----------------------------------------    2,815.99

The issue is whether the petitioner realized income in the amounts by which the face value of certain mortgage certificates issued by the petitioner's mortgagee exceed the prices at which...

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