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DELAWARE REALTY & INVESTMENT CO. v. COMMISSIONER

Docket No. 48065.

25 T.C. 51 (1955)

DELAWARE REALTY AND INVESTMENT COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 19, 1955.

Attorney(s) appearing for the Case

Percy W. Phillips, Esq., for the petitioner.

Max J. Hamburger, Esq., for the respondent.

OPINION.

WITHEY, Judge:

Respondent determined a deficiency of $1,345,373.36 in personal holding company surtax liability of petitioner for 1949.

The issues presented by the pleadings are the correctness of the respondent's action (1) in disallowing a portion of the deduction claimed for Federal income taxes for 1948 in the computation of petitioner's personal holding company subchapter A net income for 1949, and (2) in disallowing a dividends...

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