LA SALLE NATIONAL BANK v. COMMISSIONER

Docket No. 45530.

23 T.C. 479 (1954)

LA SALLE NATIONAL BANK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 14, 1954.


Attorney(s) appearing for the Case

Charles M. Nisen, Esq., and John R. Nicholson, Esq., for the petitioner.

David H. Nelson, Esq., for the respondent.


The Commissioner determined a deficiency of $42,416.63 in excess profits tax for the year 1945. The issues for decision are whether deposits by the State of Illinois, outstanding cashier's checks and bank money orders, and amounts due a broker on the purchase of Government securities constituted borrowed capital within the meaning of section 719 (a) (1) of the Internal Revenue Code, in computing petitioner's excess profits credit for 1945 and unused excess profits credit...

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