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HUT NECKWEAR COMPANY v. COMMISSIONER

Docket No. 28810.

10 T.C.M. 801 (1951)

Hut Neckwear Company v. Commissioner.

United States Tax Court.

Entered August 28, 1951.

Attorney(s) appearing for the Case

Charles Gadd, Esq., for the petitioner. William E. Murray, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined for 1946 a deficiency of $1,857.01 in income tax and one of $12,045.91 representing surtax on a corporation improperly accumulating a surplus, section 102. The latter only is contested, the petitioner contending that section 102 does not apply.

Findings of Fact

The petitioner, a New York corporation, filed its return for 1946 with the...

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