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BRADLEY v. C. I. R.

No. 9013.

324 F.2d 610 (1963)

Harris W. BRADLEY and Patricia G. Bradley, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fourth Circuit.

Decided November 11, 1963.

Attorney(s) appearing for the Case

Richard D. Obenshain and Carle E. Davis, Richmond, Va. (Thomas L. Newton, Jr., and McGuire, Woods, King, Gordon & Davis, Richmond, Va., on brief), for petitioners.

Alan D. Pekelner, Attorney, Department of Justice (Louis F. Oberdorfer, Asst. Atty. Gen., and Lee A. Jackson and Robert N. Anderson, Attorneys, Department of Justice, on brief), for respondent.

Before BRYAN and BELL, Circuit Judges, and NORTHROP, District Judge.

NORTHROP, District Judge.

In this appeal, the Bradleys, petitioners herein, seek a reversal of a decision of the Tax Court of the United States affirming a determination of the Commissioner of Internal Revenue of a deficiency assessment against them in the amount of $1,955.56 for the year 1958. The Commissioner treated as ordinary income a payment of $5,000 made by Harris W. Bradley's employer as a guarantee on the loss incurred in the sale of the Bradley home in...

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