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STANDARD OIL CO. v. COMMISSIONER

Docket No. 7512.

7 T.C. 1310 (1946)

STANDARD OIL COMPANY OF NEW JERSEY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 10, 1946.

Attorney(s) appearing for the Case

Maxwell E. McDowell, Esq., and George S. Koch, Esq., for the petitioner.

Henry C. Clark, Esq., for the respondent.

This proceeding involves a deficiency in income tax for the taxable year ended December 31, 1936, in the amount of $182,654.21. The deficiency is due to an adjustment in net income which, in the statement attached to the deficiency notice, is captioned "(a) Payment of guaranteed dividends $764,914.24" and explained by the respondent as follows:

(a) It is held that the payment, pursuant to your guarantee, in respect of dividends on Standard Oil Export Corporation 5...

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