JOY MANUFACTURING COMPANY v. COMMISSIONER

Docket No. 49773.

23 T.C. 1082 (1955)

JOY MANUFACTURING COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 31, 1955.


Attorney(s) appearing for the Case

Harold R. Schmidt, Esq., and Don Rose, Esq., for the petitioner.

Edward L. Cobb, Esq., for the respondent.


The Commissioner determined a deficiency of $55,040.44 in income tax for the petitioner's fiscal year ended September 30, 1949. The only issue for decision is whether the Commissioner erred by including engineering fees of $120,277 in income.

FINDINGS OF FACT.

The petitioner, a Pennsylvania corporation, filed its return for the taxable year with the collector of internal revenue for the twenty-third district of...

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