WISCONSIN ELECTRIC POWER COMPANY v. COMMISSIONER

Docket No. 31274.

18 T.C. 400 (1952)

WISCONSIN ELECTRIC POWER COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 23, 1952.


Attorney(s) appearing for the Case

John G. Quale, Esq., and Martin R. Paulsen, Esq., for the petitioner.

Gerald W. Brooks, Esq., for the respondent.


The Commissioner determined deficiencies in excess profits tax against the petitioner for the years 1942, 1943, and 1944 in the amounts of $534,404.40, $330,752.32, and $93,216.86. The only issue for decision is whether a loss of $376,001.32 was sustained by the petitioner in 1942 when it executed conveyances of lands embracing rights of way.

FINDINGS OF FACT.

The petitioner filed its returns for the taxable years with the collector of internal revenue for...

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