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AMES TRUST & SAVINGS BANK v. COMMISSIONER

Docket No. 14982.

12 T.C. 770 (1949)

AMES TRUST & SAVINGS BANK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 13, 1949.

Attorney(s) appearing for the Case

J. R. Austin, Esq., for the petitioner.

Frank M. Cavanaugh, Esq., for the respondent.

By this proceeding petitioner challenges respondent's determination of deficiencies in excess profits tax for the years 1943 and 1944 in the amounts of $3,603.38 and $271.07, respectively. Petitioner claims an overpayment for the year 1944 in the amount of $880.13.

The above deficiencies result from respondent's action in failing to include as borrowed invested capital 50 per cent of petitioner's daily average outstanding...

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