CARTER-COLTON CIGAR COMPANY v. COMMISSIONER

Docket No. 9123.

9 T.C. 219 (1947)

CARTER-COLTON CIGAR COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated August 20, 1947.


Attorney(s) appearing for the Case

Frank A. McCleneghan, Esq., for the petitioner.

E. M. Woolf, Esq., for the respondent.


The Commissioner determined deficiencies in petitioner's declared-value excess profits taxes and excess profits taxes for the taxable year 1943 in the amounts of $66.63 and $3,162.17, respectively. Certain adjustments made by respondent are not contested by petitioner. The amount of the deficiencies in controversy arises from respondent's determination that real estate sold by petitioner in 1943 was a capital asset.

FINDINGS OF FACT.

A partial stipulation...

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