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SPERMACET WHALING & SHIPPING CO. S/A v. COMMISSIONER

Docket No. 54931.

30 T.C. 618 (1958)

SPERMACET WHALING & SHIPPING CO. S/A, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 13, 1958.

Attorney(s) appearing for the Case

Clayton A. Quintrell, Esq., and Charles D. Leist, Esq., for the petitioner.

Frank W. Hardy, Esq., for the respondent.

ARUNDELL, Judge:

Respondent determined a deficiency in income tax for the taxable year ended April 30, 1948, in the amount of $351,492.29, all of which is in controversy. The issues to be decided are:

(1) Was petitioner, during the taxable year, a "resident * * * foreign corporation engaged in trade or business within the United States" as that phrase is used in section 231 (b), I. R. C. 1939, as amended?

(2) Did petitioner, during the taxable...

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