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EDWIN J. SCHOETTLE CO. v. COMMISSIONER

Docket No. 163.

3 T.C. 712 (1944)

EDWIN J. SCHOETTLE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 5, 1944.

Attorney(s) appearing for the Case

H. Ober Hess, Esq., and Wm. R. Spofford, Esq., for the petitioner.

Myron S. Winer, Esq., for the respondent.

OPINION.

TURNER, Judge:

The respondent has determined deficiencies in income and excess profits taxes against the petitioner for 1940 in the respective amounts of $4,636.12 and $4,225.02. The question presented is whether the petitioner is entitled to a loss deduction of $19,991.60, paid under a judgment rendered on a bond given by petitioner to secure payment of its 1917 income and excess profits taxes.

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