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TOPPS OF CANADA, LTD v. COMMISSIONER

Docket No. 72569.

36 T.C. 326 (1961)

TOPPS OF CANADA, LTD., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 23, 1961.

Attorney(s) appearing for the Case

I. Robert Rozen, Esq., and Samuel Brodsky, Esq., for the petitioner.

Charles M. Greenspan, Esq., for the respondent.

ATKINS, Judge:

The respondent determined a deficiency in income tax for the taxable year ended July 31, 1955, in the amount of $2,925.53.

The only issue is whether during the year in question the petitioner qualified as a Western Hemisphere trade corporation within the meaning of section 921 of the Internal Revenue Code of 1954, and is, therefore, entitled to the special deduction provided by section 922 of such Code.

FINDINGS OF FACT.

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