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SOUTH PORTO RICO SUGAR CO. v. COMMISSIONER

Docket No. 318.

2 T.C. 738 (1943)

SOUTH PORTO RICO SUGAR COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 24, 1943.

Attorney(s) appearing for the Case

George M. Wolfson, Esq., and C. B. Caton, Esq., for the petitioner.

Paul E. Waring, Esq., and Frank X. Gallagher, Esq., for the respondent.

This proceeding involves a redetermination of income taxes for the taxable years ended September 30, 1939, and September 30, 1940. Respondent has determined a deficiency for the two years in the respectively. amounts of $2,217.39 and $6,490.75. Conversely, petitioner claims it has overpaid each such year's tax by $49.74 and $67.30, respectively. In auditing petitioner's income tax returns for the years 1939 and 1940, respondent advised petitioner that he would disallow a...

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