CENTRAL MOTORS, INC. v. COMMISSIONER

Docket No. 41524.

13 T.C.M. 781 (1954)

T. C. Memo. 1954-122

Central Motors, Inc. v. Commissioner.

United States Tax Court.

Filed August 12, 1954.


Attorney(s) appearing for the Case

W. Scott Wilkinson, Esq., for the petitioner. W. B. Riley, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

JOHNSON, Judge:

Respondent determined deficiencies in petitioner's income tax for the calendar years 1947 and 1948 as follows:

   Year         Deficiency

  1947 .......  $44,178.15
  1948 .......   44,037.44

The issues presented for decision are as follows:

Did the Commissioner err in holding:

(1) That the petitioner in 1947 and 1948 was subject to surtax under section 102...

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