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ATLANTIC CITY ELECTRIC COMPANY v. COMMISSIONER

Docket No. 63324.

17 T.C.M. 107 (1958)

T.C. Memo. 1958-25

Atlantic City Electric Company v. Commissioner.

United States Tax Court.

Filed February 20, 1958.

Attorney(s) appearing for the Case

J. Marvin Haynes, Esq., N. Barr Miller, Esq., and Oscar L. Tyree, Esq., Investment Building, Washington, D. C., for the petitioner. Paul E. Waring, Esq., for the respondent.

Memorandum Opinion

MURDOCK, Judge:

The Commissioner determined deficiencies in income tax of $1,267,577.17 for 1952 and $110,083.27 for 1953. The Commissioner, in determining the deficiencies, gave the following explanations:

"1. It is determined that the Gross Receipts and Franchise Taxes imposed by the State of New Jersey accrue in the `privilege' year, which is the same year in which payment is due. Therefore, your deductions of these taxes for...

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