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ROSE PACKING CO. v. COMMISSIONER

Docket No. 57315.

28 T.C. 1028 (1957)

ROSE PACKING COMPANY, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 26, 1957.

Attorney(s) appearing for the Case

James J. Costello, Jr., Esq., for the petitioner.

J. Bruce Donaldson, Esq., for the respondent.

OPINION.

FORRESTER, Judge:

Respondent has determined a deficiency in petitioner's income tax for the taxable year 1950 in the amount of $1,961.94. Petitioner challenges the entire deficiency so determined, and claims an overpayment in the amount of $2,559.30. The sole issue is whether a certain payment by petitioner in 1950 in the amount of $11,110.51 is deductible in full as claimed by petitioner or, as determined by respondent, is deductible to...

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