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PHILADELPHIA TRANSPORTATION CO. v. COMMISSIONER

Docket No. 9893.

9 T.C. 1018 (1947)

PHILADELPHIA TRANSPORTATION COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 28, 1947.

Attorney(s) appearing for the Case

W. R. Spofford, Esq., Frederick L. Ballard, Esq., and Sherwin T. McDowell, Esq., for the petitioner.

Brooks Fullerton, Esq., for the respondent.

The respondent determined a deficiency in the income tax of petitioner for the calendar year 1942 in the amount of $834,982.38. The sole issue presented for our consideration is whether the petitioner, in computing the statutory "net operating loss deduction" for the year 1942, may deduct from gross income for 1940 amounts paid by it in that year in redemption of interest coupons for 1939 on its 3 per cent-6 per cent consolidated...

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