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INTERNATIONAL INVESTMENT CORPORATION v. COMMISSIONER

Docket No. 15205.

11 T.C. 678 (1948)

INTERNATIONAL INVESTMENT CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 25, 1948.

Attorney(s) appearing for the Case

David Stock, Esq., for the petitioner.

Francis X. Gallagher, Esq., for the respondent.

OPINION.

KERN, Judge:

Respondent determined a deficiency in the income tax of petitioner and its affiliated companies for the year 1942 in the amount of $16,554.98. Practically all of this deficiency resulted from respondent's determination that no recognizable loss occurred upon the distribution in liquidation made to petitioner during the taxable year by the Portage Water Co., a wholly owned subsidiary of petitioner. Petitioner alleges that respondent...

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