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RODNEY v. COMMISSIONER

Docket No. 112173.

2 T.C. 1020 (1943)

RODNEY, INCORPORATED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 24, 1943.

Attorney(s) appearing for the Case

Leo A. Diamond, Esq., for the petitioner.

S. A. Dahlquist, Esq., for the respondent.

The Commissioner determined a deficiency in petitioner's income tax in the amount of $1,372.91, a deficiency in petitioner's excess profits tax in the amount of $585.62, and in personal holding company surtax in the amount of $24,201.03, all for the calender year 1938. These deficiencies resulted from respondent's disallowance of a deduction taken by petitioner as interest paid, pursuant to section 23 (b), Revenue Act of 1938.

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