CROWN CORK INTERNATIONAL CORPORATION v. COMMISSIONER

Docket No. 1004.

4 T.C. 19 (1944)

CROWN CORK INTERNATIONAL CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 21, 1944.


Attorney(s) appearing for the Case

J. Marvin Haynes, Esq., and William T. Sherwood, Jr., Esq., for the petitioner.

Jonas M. Smith, Esq., for the respondent.


Respondent determined a deficiency of $17,981.04 in income tax and $5,416.73 in excess profits tax for the year 1939. By this proceeding petitioner challenges respondent's action in disallowing a deduction of $195,141.36 claimed by it as a loss on the sale of stock to a wholly owned subsidiary in 1939. Other adjustments have been conceded.

FINDINGS OF FACT.

The facts have been embodied in a stipulation, of which the following is a summary. Petitioner is...

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