HOME TITLE GUARANTY CO. v. COMMISSIONER

Docket No. 20631.

15 T.C. 637 (1950)

HOME TITLE GUARANTY COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 16, 1950.


Attorney(s) appearing for the Case

Hugh Satterlee, Esq., for the petitioner.

Ellyne E. Strickland, Esq., for the respondent.


In this proceeding respondent has determined a deficiency of $34,432.04 in income tax and a deficiency of $14,331.81 in excess profits tax, both for the calendar year 1945. The deficiencies result from adjustments made to petitioner's net income, invested capital, and unused excess profits credit. The only adjustment in controversy is the addition of $101,108.18 to petitioner's net income. This was explained in a statement attached to the deficiency notice, as follows:

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