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JOHNSON v. COMMISSIONER

Docket No. 106725.

1 T.C. 1041 (1943)

W. D. JOHNSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 4, 1943.

Attorney(s) appearing for the Case

John H. McEvers, Esq., Reece A. Gardner, Esq., and John M. Phillips, Esq., for the petitioner.

Angus R. Shannon, Jr., Esq., for the respondent.

This proceeding involves a deficiency in petitioner's income tax of $5,458 for the calendar year 1937. Petitioner in his petition claimed an overpayment in the amount of $291.46.

Petitioner and his wife each in separate income tax returns reported one-half of all of their income and deductions, except that petitioner reported all of the compensation received by him for personal services. The income came in part from lands in Texas and New Mexico

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