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PARTICIPATION HOLDING CO. v. COMMISSIONER

Docket No. 110245.

1 T.C. 852 (1943)

THE PARTICIPATION HOLDING COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 30, 1943.

Attorney(s) appearing for the Case

Richard C. Schaefer, Esq., for the petitioner.

W. W. Kerr, Esq., for the respondent.

This case involves income and excess profits taxes for the year 1938. Deficiencies were determined of $1,915.46 in income tax and $1,938.76 in excess profits tax. The only question presented is whether the petitioner is entitled to exemption from collection of tax under section 818 of the Revenue Act of 1938, as amended by section 406 of the Revenue Act of 1939.

FINDINGS OF FACT.

1. The petitioner, the Participation...

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