First Nat. Bank of Philadelphia v. Commissioner of Internal Revenue

McLaughlin, Circuit judge.

This is an appeal from a decision of the Tax Court, 18 T.C. 899 (August 29, 1952), upholding respondent’s determination of a deficiency for the year 1942 in the amount of $13,292.76.

The facts are not in dispute and are as follows: Petitioner is a banking association organized under federal law. At all times here material it has utilized the accrual method of accounting in reporting its federal income tax returns. For the tax years 1941 through 1945 petitioner deducted taxes levied by the Commonwealth of Pennsylvania on the value of its shares. 1 The deductions,…