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HALLBRETT REALTY CORPORATION v. COMMISSIONER

Docket No. 22630.

15 T.C. 157 (1950)

HALLBRETT REALTY CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated August 29, 1950.

Attorney(s) appearing for the Case

James A. Ronayne, Esq., for the petitioner.

Joseph F. Lawless, Esq., for the respondent.

The Commissioner determined a deficiency in income tax in the amount of $19,783.31 and a deficiency in declared value excess profits tax in the amount of $1,066.15 for the fiscal year ended November 30, 1945. The only issue for decision is whether interest accrued by the petitioner on a second mortgage for the fiscal years 1943 and 1944 was deductible in computing a net operating loss deduction for 1945.

FINDINGS OF FACT...

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