Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in income tax for the year 1939 against the Joliet & Chicago Railroad Company, petitioner herein, in the sum of $498.75. The issue is whether, under section 13 (c) of the Internal Revenue Code, petitioner is entitled to deduct 2½ per cent of the dividends paid credit in computing the amount of its additional income, received in the form of income taxes paid for it by its lessee...
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