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SUNNYHILL GARDENS, INC. v. COMMISSIONER

Docket No. 56473.

31 T.C. 24 (1958)

SUNNYHILL GARDENS, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 9, 1958.

Attorney(s) appearing for the Case

William Walzer, Esq., for the petitioner.

Martin D. Cohen, Esq., for the respondent.

OPINION.

RAUM, Judge:

The Commissioner determined a deficiency in income tax in the amount of $31,837.37 for the year 1951. Petitioner is a corporation on an accrual basis that was organized in April 1950 to construct and own certain apartment buildings with the assistance of a mortgage loan to be guaranteed by the Federal Housing Administration. An F. H. A. "commitment" had already been obtained with respect...

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