LAB ESTATES, INC. v. COMMISSIONER

Docket No. 18595.

13 T.C. 811 (1949)

LAB ESTATES, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 29, 1949.


Attorney(s) appearing for the Case

Walter F. Sloan, Esq., and Z. N. Diamond, Esq., for the petitioner.

J. Richard Riggles, Jr., Esq., for the respondent.


This proceeding involves a deficiency of $32,265.74 in excess profits tax asserted against the petitioner for the year 1944. The question for our determination is whether the total amount of rent arrearage forgiven by the petitioner-landlord is an allowable deduction in computing its taxable net income for that year. In the alternative, petitioner argues that, if the total amount of rent arrearage forgiven in 1944 is not deductible, then the rentals which became payable...

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