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CENTURY ELECTRIC CO. v. COMMISSIONER

Docket No. 108667.

3 T.C. 297 (1944)

CENTURY ELECTRIC COMPANY, A CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 18, 1944.

Attorney(s) appearing for the Case

Davis Haskin, Esq., for the petitioner.

W. Frank Gibbs, Esq., for the respondent.

SUPPLEMENTAL OPINION.

TURNER, Judge:

As originally presented, the only issue in this proceeding was whether, for the purpose of determining the surtax on its undistributed profits, the petitioner was entitled to certain credits under section 26 (c) (2) of the Revenue Act of 1936, because of a contract restricting the payment of dividends. On November 30, 1942, this Court entered its memorandum opinion deciding the issue against the petitioner, and...

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