320 E. 47TH STREET CORPORATION v. COMMISSIONER

Docket No. 54252.

26 T.C. 545 (1956)

320 E. 47TH STREET CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 13, 1956.


Attorney(s) appearing for the Case

Lester R. Bachner, Esq., for the petitioner.

Charles M. Greenspan, Esq., for the respondent.


This proceeding involves a deficiency in personal holding company tax in the amount of $15,729.33 for the year 1950.

The only issue is whether 80 per cent or more of the petitioner's gross income for the year 1950 consisted of personal holding company income as defined by section 502 of the 1939 Code.

Some of the facts were stipulated.

FINDINGS OF FACT.

The stipulated facts are so found and are incorporated...

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