SAN MARCOS HOTEL COMPANY v. COMMISSIONER

Docket No. 25618.

11 T.C.M. 388 (1952)

San Marcos Hotel Company v. Commissioner.

United States Tax Court.

April 18, 1952.


Attorney(s) appearing for the Case

William D. Morrison, Esq., 840 San Diego Trust & Savings Bldg., San Diego, Calif., for the petitioner. H. A. Melville, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

JOHNSON, Judge:

Respondent determined a deficiency of $25,669.05 in excess profits tax for the calendar year 1944.

The issues are: (1) whether respondent erred in decreasing petitioner's equity invested capital from $375,000 to $75,000 to compute its excess profits credit for the calendar years 1942, 1943 and 1944; (2) whether respondent erred in determining that the forgiveness by the mortgagee of indebtedness...

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