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PAXSON v. COMMISSIONER

Docket No. 109648.

2 T.C. 819 (1943)

JOSEPH A. PAXSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 30, 1943.

Attorney(s) appearing for the Case

Aaron Smith, C. P. A., for the petitioner.

Robert S. Garnett, Esq., for the respondent.

The respondent determined deficiencies in income tax for the years 1936, 1937, and 1938 in the amounts of $2,169.47, $3,973.88, and $3,101.36, respectively. The deficiencies arise from the inclusion of certain commissions in the petitioner's taxable income, and the issue presented is whether the commissions are income of the petitioner or income of Albany Service Station, Inc., a corporation owned by the petitioner and members of his...

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