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CONTINENTAL TRADING INC. v. COMMISSIONER

Docket No. 55212.

16 T.C.M. 724 (1957)

T.C. Memo. 1957-164

Continental Trading Inc. v. Commissioner.

United States Tax Court.

Filed August 30, 1957.

Attorney(s) appearing for the Case

M. W. Dobrzensky, Esq., Central Bank Building, Oakland, Calif., and S. H. Dobrzensky, Esq., for the petitioner. Aaron S. Resnik, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

OPPER, Judge:

Respondent determined the following deficiencies in income tax:

  Year                      Deficiency

  1948 .................   $208,300.59
  1949 .................    151,559.71
  1950 .................    114,468.53

The principal issue is whether petitioner qualified as a resident foreign corporation during the years involved by engaging in trade or business within the...

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