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PAN AMERICAN TRUST COMPANY v. COMMISSIONER

Docket No. 4474.

4 T.C.M. 555 (1945)

Pan American Trust Company v. Commissioner.

United States Tax Court.

Entered May 28, 1945.

Attorney(s) appearing for the Case

Max Rolnik, C. P. A., 21 West St., New York 6. N. Y., for the petitioner. Ellyne E. Strickland, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

OPPER, Judge:

This proceeding was brought for a redetermination of a deficiency in petitioner's income tax for the year 1941 in the sum of $2,052.83. Only one issue is contested, that being whether a transaction entered into by petitioner pursuant to a plan of The Baltimore and Ohio Railroad Company for modification of interest charges and maturities on certain of its secured notes held by petitioner was within the...

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