United States Board of Tax Appeals July 12, 1940, Docket Nos. 94218, 95837, 95838, 95839. (Pembroke Realty & Sec. Corp. v. Commissioner)

lead-opinion

*348OPINION.

OrrER:

The corporate petitioner is a personal holding company within the meaning of section 351 of the Eevenue Act of 1934. It has claimed deductions from its “adjusted net income” under that section on account of certain amounts assertedly distributed as dividends,1 and for others as being “used or set aside to retire indebtedness incurred prior to January 1, 1934.