PERNOT CORPORATION v. COMMISSIONER

Docket No. 15179.

8 T.C.M. 722 (1949)

Pernot Corporation, formerly Pernot and Rich, Inc., a California corporation v. Commissioner.

United States Tax Court.

Entered August 16, 1949.


Attorney(s) appearing for the Case

Wareham C. Seaman, Esq., for the petitioner. Robert H. Kinderman, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

The respondent determined deficiencies of $6,458.57 and $48.25 in the petitioner's excess profits tax and declared value excess profits tax, respectively, for the fiscal year ending October 31, 1944.

The single issue is whether or not the petitioner is entitled to deduct from its gross income for the fiscal years ending October 31, 1943 and October 31, 1944, amounts representing operating losses of a partnership allegedly...

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