Raffold Process Corp. v. Commissioner of Internal Revenue

WOODBURY, Circuit Judge.

These consolidated petitions for review of two decisions of the Tax Court of the United States raise the question of the de-ductibility from income, personal holding company, and declared value excess profits taxes of advances made by the two petitioning corporations to a third under the following circumstances.

Harold R. Rafton, formerly the owner of a chemical laboratory specializing in problems arising from the use of carbonate fillers in paper, and also the owner of a number of domestic and foreign (European and Canadian) patents covering processes for the use of…