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FIDELITY-PHILADELPHIA TRUST CO. v. COMMISSIONER

Docket No. 43719.

23 T.C. 527 (1954)

FIDELITY-PHILADELPHIA TRUST COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 27, 1954.

Attorney(s) appearing for the Case

Alfred J. McDowell, Esq., and John Anthony Day, Esq., for the petitioner.

George H. Bowers, Jr., Esq., for the respondent.

OPINION.

RAUM, Judge:

The Commissioner determined a deficiency of $3,593.74 in income tax for the year 1948. The question for decision is whether $6,780.64 in unclaimed and dormant deposits in the taxpayer bank represented income when in 1948 it transferred that amount from its deposit liability account to surplus. The facts have been stipulated, and the stipulation is incorporated herein by reference as our...

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