G & J Investment Corp. v. Commissioner of Internal Revenue

PHILLIPS, Chief Judge.

G & J Investment Corp. (taxpayer) appeals from a decision of the United States Tax Court upholding the Commissioner’s determination of income tax deficiencies in the amounts of $5,000 and $5,500 for the years 1967 and 1968, respectively. We affirm.

For a comprehensive statement of the facts, reference is made to the Tax Court opinion prepared by Judge Theodore Tannenwald, Jr. 42 P-H Tax Ct. Mem.'1049 (1973).

The question before us is whether taxpayer was entitled to a separate corporate surtax exemption for the years in question under § 1551 of the Internal Revenue Code…