INVESTORS' MORTGAGE SECURITY COMPANY, LIMITED v. COMMISSIONER

Docket No. 2278.

4 T.C.M. 45 (1945)

The Investors' Mortgage Security Company, Limited v. Commissioner.

United States Tax Court.

Entered January 17, 1945.


Attorney(s) appearing for the Case

Marion N. Fisher, Esq., 15 Broad St., New York, N. Y., for the petitioner. Lester M. Ponder, Esq., for the respondent.


The Commissioner determined deficiencies of $2,542.31, $1,687.65, $978.17 and $704.04 in income tax for the fiscal years ending September 30, 1937, 1938, 1939 and 1941. The petitioner assails the determination that it is taxable as a nonresident foreign corporation under Section 231(a) of the Revenue Acts of 1936 and 1938, and Internal Revenue Code, and contends that it was engaged in trade or business within the United States.

Findings of Fact

The petitioner...

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