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SOUTHERN BANK OF NORFOLK v. COMMISSIONER

Docket No. 29543.

11 T.C.M. 47 (1952)

Southern Bank of Norfolk, a Banking Corporation Organized and Existing Under the Laws of the State of Virginia v. Commissioner.

United States Tax Court.

Entered January 22, 1952.

Attorney(s) appearing for the Case

Edward L. Breeden, Jr., Esq., for the petitioner. J. Nelson Anderson, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The respondent determined a deficiency in excess profits tax for the year 1945 in the amount of $8,904.19.

The sole question presented for our determination is whether amounts on deposit in the bank of petitioner, evidenced by deposit agreements, certificates of deposit. and savings deposits constitute borrowed invested capital within the meaning of Section 719 of the Internal Revenue Code.

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