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SANATORIUM v. COMMISSIONER

Docket No. 36540.

20 T.C. 1099 (1953)

GLENWOOD SANATORIUM, A CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 30, 1953.

Attorney(s) appearing for the Case

R. Shad Bennett, Esq., for the petitioner.

Marvin E. Hagen, Esq., for the respondent.

Respondent determined deficiencies in petitioner's income taxes of $7,427.92 and $6,045.80 for the taxable years ended January 31, 1949, and January 31, 1950, respectively. The sole issue is whether petitioner is precluded by section 24 (c) of the Internal Revenue Code from deducting rental expenses of $19,000 and $24,000, respectively, for the years in controversy.

FINDINGS OF FACT.

Petitioner is a corporation...

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