NATIONAL BANK OF COMMERCE OF SEATTLE v. COMMISSIONER

Docket No. 12508.

12 T.C. 717 (1949)

THE NATIONAL BANK OF COMMERCE OF SEATTLE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 6, 1949.


Attorney(s) appearing for the Case

Thomas N. Fowler, Esq., for the petitioner.

Douglas L. Barnes, Esq., for the respondent.


The respondent determined a deficiency in petitioner's income tax for the years 1942 and 1943 in the respective amounts of $6,921.73 and $7,867.94. The deficiency is primarily due to the addition to petitioner's net income in the taxable years 1942 and 1943 of the respective amounts of $17,304.33 and $13,528.26 which were designated by it in its return as stockholders' contributions. These adjustments are explained in the deficiency notice as follows:

(a) It is held...

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