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WILLARD HELBURN, INC. v. COMMISSIONER

Docket No. 38865.

20 T.C. 740 (1953)

WILLARD HELBURN, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 30, 1953.

Attorney(s) appearing for the Case

Arnold R. Cutler, Esq., LaRue Brown, Esq., and George B. Lourie, Esq., for the petitioner.

Lester H. Salter, Esq., for the respondent.

OPINION.

MURDOCK, Judge:

The Commissioner determined a deficiency of $42,461.82 in income tax of the petitioner for its fiscal year ended November 30, 1949. The only issue for decision is whether the petitioner realized taxable income of $84,047.36, the difference between the dollar value of pounds sterling borrowed to purchase skins and dollars expended to purchase pounds sterling to repay the loan. The facts have been presented by a stipulation...

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