GENERAL RETAIL CORPORATION v. COMMISSIONER

Docket No. 55272.

29 T.C. 632 (1957)

GENERAL RETAIL CORPORATION (DELAWARE), PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 31, 1957.


Attorney(s) appearing for the Case

J. W. Allen, Esq., and William Waller, Esq., for the petitioner.

Jack D. Yarbrough, Esq., for the respondent.


Respondent determined a deficiency of $18,504.93 in petitioner's income (excess profits) tax for its taxable year ended October 31, 1951. The only issue is whether petitioner is entitled to compute its excess profits tax as a new corporation under section 430 (e) (1), I. R. C. 1939.

FINDINGS OF FACT.

Certain facts are stipulated and are hereby found.

Petitioner, chartered under the laws of the State of Delaware on September 30, 1948, maintained its...

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