J. A. RIGGS TRACTOR COMPANY v. COMMISSIONER

Docket Nos. 4430, 6358.

6 T.C. 889 (1946)

J. A. RIGGS TRACTOR COMPANY (A PARTNERSHIP, BY JOHN A. RIGGS, SR., AND JOHN A. RIGGS, JR., PARTNERS, INDIVIDUALLY AND AS TRUSTEES), PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 29, 1946.


Attorney(s) appearing for the Case

Preston B. Kavanagh, Esq., and Lamar Williamson, Esq., for the petitioner.

J. Marvin Kelley, Esq., for the respondent.


In these consolidated proceedings respondent determined that the J. A. Riggs Tractor Co. is an association taxable as a corporation and proposed tax deficiencies as follows:

--------------------------------------------------------------------------------------------
                                              |            | Excess profits | Declared value
         Fiscal year ended Oct. 31—          | Income tax |      tax       | excess profits
 ...

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