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HEARST CORPORATION v. COMMISSIONER

Docket No. 19786.

14 T.C. 575 (1950)

THE HEARST CORPORATION, TRANSFEREE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 10, 1950.

Attorney(s) appearing for the Case

Ward E. Lattin, Esq., for the petitioner.

John J. Madden, Esq., for the respondent.

OPINION.

OPPER, Judge:

A deficiency in personal holding company surtax of Hearst Estate, Inc., for 1941 in the amount of $15,718.97 has been determined against petitioner as transferee. The transferee liability is conceded and the questions are whether payments of interest made by petitioner's transferor on money borrowed by it for the benefit of its parent are deductible either as such or as dividends; and whether, if not, the statute of limitations...

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