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FIRST NATIONAL BANK OF PHILADELPHIA v. COMMISSIONER

Docket Nos. 26824, 32174.

18 T.C. 899 (1952)

THE FIRST NATIONAL BANK OF PHILADELPHIA, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated August 26, 1952.

Attorney(s) appearing for the Case

Robert C. Lea, Jr., Esq., for the petitioner.

Brooks Fullerton, Esq., for the respondent.

OPINION.

BRUCE, Judge:

Respondent has determined a deficiency in income tax of $13,292.76 for the taxable year 1942. The facts are stipulated and are so found, but only so much of the detailed stipulation is hereinafter set out as is necessary to an understanding of the issue presented, which is the method of computation to be used in computing the deficiency by application of section 3801 of the Internal Revenue Code1

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