NATIONAL BANK OF COMMERCE v. COMMISSIONER

Docket No. 27771.

16 T.C. 769 (1951)

NATIONAL BANK OF COMMERCE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 13, 1951.


Attorney(s) appearing for the Case

Thomas J. Reilly, Esq., for the petitioner.

D. Louis Bergeron, Esq., for the respondent.


The Commissioner has determined a deficiency in petitioner's excess profits tax liability for the calendar year 1945 in the amount of $91,077.77.

The only part of the deficiency in contest results from respondent's adjustment of petitioner's borrowed invested capital for determining petitioner's excess profits credit for the calendar year 1945 and its unused excess profits credit carry-over for the calendar year 1943. This adjustment was explained in the deficiency...

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