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WARREN BROWNE, INC. v. COMMISSIONER

Docket No. 22176.

14 T.C. 1056 (1950)

WARREN BROWNE, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 5, 1950.

Attorney(s) appearing for the Case

Forrest M. Hemker, Esq., for the petitioner.

Marvin E. Hagen, Esq., for the respondent.

Respondent determined deficiencies in personal holding company surtax against petitioner in the amount of $2,772.96 for the fiscal year ended August 31, 1945, and in the amount of $9,216.39 for the fiscal year ended August 31, 1946.

The sole question is whether the income received by petitioner for the taxable years constitutes personal holding company income under the provisions of section 502 (a) of the Internal Revenue...

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