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BARTELL HOTEL CO., INC. v. COMMISSIONER

Docket No. 67974.

32 T.C. 311 (1959)

THE BARTELL HOTEL CO., INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 30, 1959.

Attorney(s) appearing for the Case

Thomas J. Kennedy, Esq., and E. S. Hampton, Esq., for the petitioner.

Sylvan Siegler, Esq., for the respondent.

MULRONEY, Judge:

The respondent determined deficiencies in income tax of petitioner for the years 1951, 1952, and 1953 in the respective amounts of $30,547.03, $13,502.60, and $5,741.79, together with additions to the tax under section 291(a) of the Internal Revenue Code of 1939 for the taxable years 1952 and 1953 in the respective amounts of $4,616.32 and $1,435.45.

The principal issue involved is whether income derived from the operation of a hotel...

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