ROLLINS BURDICK HUNTER CO. v. COMMISSIONER

Docket No. 11691.

9 T.C. 169 (1947)

ROLLINS BURDICK HUNTER CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated August 6, 1947.


Attorney(s) appearing for the Case

Raymond H. Schultz, Esq., for the petitioner.

Jackson L. Boughner, Esq., for the respondent.


OPINION.

MURDOCK, Judge:

The Commissioner determined deficiencies in income tax of $157.14 and $2,532.01 for 1942 and 1943, and a deficiency of $1,908.32 in excess profits tax for 1943. The only issue for decision is whether the petitioner was dealing in its own stock as it might in the stock of another and, therefore, realized taxable gains from sales of its own stock in each taxable year. The facts have been stipulated.

The petitioner is...

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