SAN FRANCISCO STEVEDORING CO. v. COMMISSIONER

Docket No. 7775.

8 T.C. 222 (1947)

THE SAN FRANCISCO STEVEDORING CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated January 30, 1947.


Attorney(s) appearing for the Case

Arthur H. Kent, Esq., and Valentine Brooks, Esq., for the petitioner.

T. M. Mather, Esq., A. James Hurley, Esq., and Paul E. Treusch, Esq., for the respondent.


OPINION.

MURDOCK, Judge:

The Commissioner determined a deficiency of $2,928.81 in the petitioner's excess profits tax for the calendar year 1942. The first issue for decision is whether $5,499.24 should have been accrued as income for the year 1939, thus increasing the income of the base period. The facts have been stipulated and the stipulation is adopted as the findings of fact.

The petitioner is...

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