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SPECIALTY ENGINEERING CO. v. COMMISSIONER

Docket Nos. 18133, 18627.

12 T.C. 1173 (1949)

SPECIALTY ENGINEERING COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. JOHN G. OGDEN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 30, 1949.

Attorney(s) appearing for the Case

Clement J. Clarke, Jr., Esq., and James Moore, Esq., for the petitioner in Docket No. 18133.

George V. Strong, Esq., and John H. Zebley, Jr., C. P. A., for the petitioner in Docket No. 18627.

William D. Harris, Esq., for the respondent.

OPINION.

MURDOCK, Judge:

The Commissioner determined deficiencies for 1944 of $6,115.80 in income tax, $719.63 in declared value excess profits tax, and $73,900.10 in excess profits tax of Specialty Engineering Co., hereinafter called Specialty. The errors assigned by Specialty are the action of the Commissioner in disallowing (1) a deduction of $140,000 paid to John G. Ogden in settlement of a judgment; (2) a deduction of $13,509.35 representing...

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