WAYNE TITLE & TRUST COMPANY v. COMMISSIONER

Docket No. 25318.

16 T.C. 924 (1951)

THE WAYNE TITLE & TRUST COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 30, 1951.


Attorney(s) appearing for the Case

Charles S. Jacobs, Esq., for the petitioner.

Lester H. Salter, Esq., for the respondent.


This proceeding involves the redetermination of an income tax deficiency for the calendar year 1946. The amount in controversy is $766.92 of which $81.33 represents the deficiency determined by respondent and $685.59 represents the overpayment claimed by petitioner.

FINDINGS OF FACT.

The facts were stipulated, are so found and made a part hereof.

Petitioner is a corporation organized and existing under the...

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