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JOAN CAROL CORPORATION v. COMMISSIONER

Docket No. 20725.

13 T.C. 83 (1949)

JOAN CAROL CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated July 15, 1949.

Attorney(s) appearing for the Case

Jay O. Kramer, Esq., for the petitioner.

John J. Madden, Esq., for the respondent.

OPINION.

DISNEY, Judge:

This case involves personal holding company surtax liability for the fiscal year ended May 31, 1946. Deficiency was determined in the amount of $17,813.58. The sole question presented is whether the taxpayer, upon the cash basis, may, in computing its subchapter A net income, deduct Federal income taxes accrued for the taxable year but not paid in that year. The petitioner filed its return for the taxable year with the collector...

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