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CAULKINS v. COMMISSIONER

Docket No. 108422.

1 T.C. 656 (1943)

GEORGE PECK CAULKINS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 25, 1943.

Attorney(s) appearing for the Case

Hugh W. Allin, Esq., Arthur T. Iverson, Esq., and J. K. Starr, Esq., for the petitioner.

Lawrence R. Bloomenthal, Esq., for the respondent.

The Commissioner made several adjustments to the net income shown in petitioner's return for the calendar year 1939 and determined a deficiency in income tax in the amount of $1,505.59. The sole issue raised by the pleadings is whether the excess of the amount received by petitioner, pursuant to a contract with Investors Syndicate, over the aggregate payments made by him constituted ordinary income or capital gain.

FINDINGS...

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