THE KIRLIN COMPANY v. COMMISSIONER

Docket No. 93508.

23 T.C.M. 1580 (1964)

T.C. Memo. 1964-260

The Kirlin Company v. Commissioner.

United States Tax Court.

Filed September 30, 1964.


Attorney(s) appearing for the Case

Edgar W. Pugh, 3353 Penobscot Bldg., Detroit, Mich., and Albert Moehlman, for the petitioner. Robert W. Siegel, for the respondent.


Memorandum Findings of Fact and Opinion

FISHER, Judge:

Respondent determined a deficiency in income tax against the above-named petitioner for its fiscal year ending August 31, 1958, in the amount of $103,439.33.

The sole issue for decision is whether petitioner is subject to the tax imposed by section 531 of the 1954 Internal Revenue Code,1 on the ground that it was...

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