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AMO REALTY CO. v. COMMISSIONER

Docket No. 48839.

24 T.C. 812 (1955)

AMO REALTY COMPANY, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 29, 1955.

Attorney(s) appearing for the Case

Alfred Swedlaw, Esq., and Samuel Tenenbaum, Esq., for the petitioner.

Lester R. Uretz, Esq., for the respondent.

This proceeding involves a deficiency in personal holding company tax in the amount of $8,253.60 and a penalty under section 291 (a) of the 1939 Code in the amount of $2,063.40 determined by the respondent for the year 1945.

The issues are: (1) Whether petitioner's income for the year 1945 was personal holding company income as defined by section 502 (f);1 and (2) if so, whether petitioner's failure...

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