HANCOCK CTY. FEDERAL SAVINGS & LOAN ASSN. v. COMMISSIONER

Docket No. 61243.

32 T.C. 869 (1959)

HANCOCK COUNTY FEDERAL SAVINGS AND LOAN ASSOCIATION OF CHESTER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 30, 1959.


Attorney(s) appearing for the Case

James C. Herndon, Esq., and Sam D. Bartlo, Esq., for the petitioner.

William O. Allen, Esq., for the respondent.


The Commissioner determined deficiencies in income tax for the taxable years 1952 and 1953 in the amounts of $12,469.23 and $9,725.83, respectively. The question is whether, under section 23(r) (1), 1939 Code, dividends declared by petitioner on its earnings for the 6-month period ended December 31, 1951, are deductible in 1952.

FINDINGS OF FACT.

Petitioner is a Federal savings and loan association. Its office is located in Chester, West Virginia. Petitioner...

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