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STANDARD OIL COMPANY OF NEW JERSEY v. COMMISSIONER

Docket No. 7512.

11 T.C. 843 (1948)

STANDARD OIL COMPANY OF NEW JERSEY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 29, 1948.

Attorney(s) appearing for the Case

Marion N. Fisher, Esq., D. Nelson Adams, Esq., Maxwell E. McDowell, Esq., and George S. Koch, Esq., for the petitioner.

Henry C. Clark, Esq., for the respondent.

This is a reconsideration of our report published at 7 T.C. 1310. After the promulgation of that report petitioner filed a "Motion for Reopening of Case to Permit Introduction of Evidence and Rehearing," on the ground that our holding that petitioner could not deduct the payment in question to Export of guaranteed dividends of $764,914.24, because it impliedly had a valid enforceable claim against Export for reimbursement, was a holding on...

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