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AMBASSADOR, INC. v. COMMISSIONER

Docket No. 29629.

11 T.C.M. 974 (1952)

Ambassador, Inc. (Formerly 14th Street Development Company) v. Commissioner.

United States Tax Court.

Entered September 30, 1952.

Attorney(s) appearing for the Case

Harry J. Rudick, Esq., 25 Broadway, New York, N. Y., and Joyce Stanley, Esq., for the petitioner. Paul E. Waring, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

HARRON, Judge:

The Commissioner has determined deficiencies in excess profits taxes for the years 1944 and 1945 in the respective amounts of $118,556.51 and $253,102.18.

The Commissioner has determined that for the purpose of computing the excess profits credit of the petitioner allowable for the years 1942 to 1945, inclusive, the gain realized on the sale of Corcoran Courts Apartments in 1938 represented capital...

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