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BROOKLYN NATIONAL CORPORATION v. COMMISSIONER

Docket No. 5959.

5 T.C. 892 (1945)

THE BROOKLYN NATIONAL CORPORATION (IN LIQUIDATION), PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 9, 1945.

Attorney(s) appearing for the Case

Meyer Kraushaar, Esq., and John Scott Stella, Esq., for the petitioner.

E. E. Strickland, Esq., for the respondent.

OPINION.

MURDOCK, Judge:

The Commissioner determined a deficiency of $8,047.33 in personal holding company surtax for the calendar year 1941. The issues for decision are whether the petitioner was a personal holding company during 1941 and, even if it was, whether it was liable for any personal holding company surtax in view of the fact that it was dissolved during the year and made a substantial distribution...

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