Wilson Bros. & Co. v. Commissioner of Internal Revenue

ORR, Circuit Judge.

This cause is before us on a petition for a review of a decision of the Tax Court making a redetermination of deficiencies determined by the commissioner of per sonal holding company surtax for the calendar years 1938 to 1942. It is conceded that petitioner is a personal holding company as defined by § 501 of the Internal Revenue Code, 26 U.S.C.A.

The Tax Court affirmed a determination of the Commissioner of Internal Revenue that for the purpose of computing the personal holding company surtax the petitioner was not entitled to deduct, under the provisions of § 505(b) of the…