GENERAL AMERICAN INVESTORS COMPANY, INC. v. COMMISSIONER

Docket No. 36220.

19 T.C. 581 (1952)

GENERAL AMERICAN INVESTORS COMPANY, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 30, 1952.


Attorney(s) appearing for the Case

Robert A. McDowell, Esq., for the petitioner.

Arthur L. Nims, Esq., for the respondent.


Respondent determined a deficiency of $57,922.55 for the calendar year 1948. By appropriate assignment of error petitioner contests the entire deficiency and alleges the following error:

The Commissioner erroneously determined that the petitioner realized taxable income of $157,038.04 by its receipt in 1948 of $170,038.04 (in connection with the receipt of which it was entitled to an allowance of legal expenses of at least $13,000 which it did not deduct on its return...

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