Although this proceeding was commenced nearly eleven years ago it was submitted to the court at the May, 1951, Term. On May 14, 1937, petitioner filed its franchise tax return for the base year 1936 for the tax year commencing November 1, 1937. It deducted as an item chargeable against income the sum of $807,503.98 which was interest accrued and owing to two corporations which were its stockholders. Its return thereby showing a net loss it paid a tax of $2,405.14 based on...
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