NEW JERSEY MORTGAGE AND TITLE CO. v. COMMISSIONER

Docket No. 109011.

3 T.C. 1277 (1944)

NEW JERSEY MORTGAGE AND TITLE CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated August 28, 1944.


Attorney(s) appearing for the Case

Charles P. Swindler, Esq., and Sydney A. Gutkin, Esq., for the petitioner.

Robert S. Garnett, Esq., for the respondent.


The respondent has found a deficiency of $8,277.76 in income tax for petitioner's fiscal year ended February 28, 1938, and of $414.26 for the year 1939, a total of $8,692.02. The pleadings in the case present several questions; but by respondent's motion and our order of March 17, 1943, severing other issues in the case, we have left for determination here only the question of whether the reorganization of petitioner's predecessor corporation, Guarantee Mortgage & Title...

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