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UNIVERSAL CONSOLIDATED OIL COMPANY v. COMMISSIONER

Docket No. 85372.

20 T.C.M. 1285 (1961)

T.C. Memo. 1961-246

Universal Consolidated Oil Company v. Commissioner.

United States Tax Court.

Filed August 31, 1961.

Attorney(s) appearing for the Case

Richard F. Alden, Esq., 900 Wilshire Blvd., Los Angeles, Calif., for the petitioner. Marion Malone, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

The Commissioner determined a deficiency in income tax of $79,629.32 for 1956. The issues presented are (1) whether loans made by petitioner to its wholly-owned subsidiary became worthless in 1956; and (2) whether petitioner's investment in the capital stock of the subsidiary became worthless in 1956.

Findings of Fact

The stipulated...

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