ATCHISON, TOPEKA AND SANTA FE RAILWAY CO. v. COMMISSIONER

Docket No. 73138.

36 T.C. 584 (1961)

THE ATCHISON, TOPEKA AND SANTA FE RAILWAY COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 29, 1961.


Attorney(s) appearing for the Case

William P. Tilton, Jr., Esq., Charles B. McInnis, Esq., G. Kibby Munson, Esq., Roger H. Muzzall, Esq., John J. Schmidt, Esq., and Jonathan C. Gibson, Esq., for the petitioner.

Don S. Harnack, Esq., Cornelius C. Shields, Esq., and Theodore W. Hirsh, Esq., for the respondent.


TIETJENS, Judge:

The respondent determined deficiencies in income tax for the calendar years 1948 and 1949 in the respective amounts of $1,216,173.51 and $1,377,204.78. The sole issue remaining for decision is whether the respondent erred in determining that the petitioner should have accrued additional interest income from a subsidiary in those years.

The petitioner's corporation income tax returns for 1948 and 1949 were filed with the collector of...

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