SHERATON PLAZA CO. v. COMMISSIONER

Docket No. 89380.

39 T.C. 697 (1963)

SHERATON PLAZA COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 18, 1963.


Attorney(s) appearing for the Case

Robert J. Richards, Jr., Esq., for the petitioner.

Albert R. Doyle, Esq., and John C. Galluzzo, Jr., Esq., for the respondent.


Respondent determined a deficiency in income tax for the fiscal year ending April 30, 1954, of $37,557.19. The deficiency is based solely upon the determination that petitioner realized income upon the cancellation of indebtedness owed to its sole shareholder. The parties have stipulated some of the facts.

FINDINGS OF FACT.

The stipulated facts are hereby found accordingly.

Petitioner is a corporation organized under the laws of the Commonwealth...

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