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ABBOTT MORTGAGE CO. v. COMMISSIONER

Docket No. 62243.

17 T.C.M. 542 (1958)

T.C. Memo. 1958-106

Abbott Mortgage Company, Petitioner v. Commissioner.

United States Tax Court.

Filed June 9, 1958.

Attorney(s) appearing for the Case

Sidney B. Gambill, Esq., Union Trust Building, Pittsburgh, Pa., for the petitioner. Gerald Backer, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

The Commissioner determined the following deficiencies in income tax of petitioner:

  1952 ............    $11,756.77
  1953 ............     12,216.27
  1954 ............      9,556.62

Two questions are presented for decision: (1) whether the Commissioner properly allocated to petitioner income and deductions which were reported and claimed by J. D. Abbott Company for the...

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