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UNITED GAS IMPROVEMENT CO. v. COMMISSIONER

Docket No. 39315.

25 T.C. 229 (1955)

UNITED GAS IMPROVEMENT COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 31, 1955.

Attorney(s) appearing for the Case

Leonard A. Spalding, Jr., Esq., and John A. Day, Esq., for the petitioner.

Stephen P. Cadden, Esq., for the respondent.

OPINION.

MULRONEY, Judge:

The respondent determined deficiencies in income tax of petitioner for the taxable year 1947 in the sum of $711.20, and 1948 in the sum of $242,058.95. The petitioner seeks a determination that there is no deficiency but overpayments instead.

Petitioner, a Pennsylvania corporation, holding company, with its principal place of business in Philadelphia, Pennsylvania, filed its consolidated Federal income tax returns...

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