SMITH-BRIDGMAN & COMPANY v. COMMISSIONER

Docket No. 21357.

16 T.C. 287 (1951)

SMITH-BRIDGMAN & COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 5, 1951.


Attorney(s) appearing for the Case

N. Barr Miller, Esq., for the petitioner.

A. J. Friedman, Esq., for the respondent.


This proceeding involves deficiencies in income and excess profits taxes for the taxable year ended January 31, 1944, in the respective amounts of $33.12 and $18,185.

The issues are:

1. Whether the respondent erred in adding the amount of $5,865.50 to the taxable income of petitioner, as allegedly constituting interest which respondent asserts should have been charged by petitioner on non-interest-bearing loans to its parent corporation, pursuant to the provisions...

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