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PITTSBURGH & WEST VIRGINIA RAILWAY COMPANY v. COMMISSIONER

Docket No. 11116.

9 T.C. 268 (1947)

THE PITTSBURGH & WEST VIRGINIA RAILWAY COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated August 29, 1947.

Attorney(s) appearing for the Case

W. A. Seifert, Esq., and N. D. Keller, Esq., for the petitioner.

A. W. Dickinson, Esq., for the respondent.

By this proceeding petitioner challenges respondent's determination of deficiencies in income tax for the calendar years 1941 and 1942 in the respective amounts of $109,643.16 and $56,620.29. Four questions are presented:

(1) Whether, under the circumstances, petitioner derived taxable income in 1941 and 1942 as a result of its purchase of a number of its bonds at amounts less than issue price.

(2) Whether petitioner...

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