COMMISSIONER OF INT. REV. v. F. P. E. NOTEHOLDERS CORP.

No. 10203.

157 F.2d 982 (1946)

COMMISSIONER OF INTERNAL REVENUE v. F. P. E. NOTEHOLDERS CORPORATION.

Circuit Court of Appeals, Sixth Circuit.

November 18, 1946.


Attorney(s) appearing for the Case

Harry Baum, of Washington, D. C. (Sewall Key, Helen R. Carloss, and Lee A. Jackson, all of Washington, D. C., on the brief), for petitioner.

Kurt J. Kremlick, of Detroit, Mich., for respondent.

Before HICKS, MARTIN, and MILLER, Circuit Judges.


MILLER, Circuit Judge.

The Commissioner of Internal Revenue seeks a review of the ruling of The Tax Court of August 30, 1945, holding that there is a deficiency in taxpayer's income tax for the fiscal year ending October 31, 1941, of $668.07. The Commissioner contends that the deficiency should have been found to be income tax in the amount of $2,973.77 and declared value excess-profits tax in the amount of $116.91.

The reduction in the deficiency assessment...

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