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SHAFFER TERMINALS, INC. v. COMMISSIONER

Docket No. 26127.

16 T.C. 356 (1951)

SHAFFER TERMINALS, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 16, 1951.

Attorney(s) appearing for the Case

Henry C. Perkins, Esq., for the petitioner.

John D. Picco, Esq., for the respondent.

Respondent has determined deficiencies in excess profits tax for the years 1944 and 1945 in the amounts of $20,537.77 and $22,220.52, respectively.

The only issue before us is whether respondent erred in disallowing deductions taken by petitioner in 1944 and 1945 for amounts paid as rent on equipment under certain "Sale and Lease Agreements" entered into with stockholders of petitioner, doing business as Equipment Associates, a partnership.

FINDINGS OF FACT...

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