NIELSEN v. COMMISSIONER

Docket Nos. 4341, 4342.

3 T.C.M. 1333 (1944)

N. Nielsen v. Commissioner. Louise Nielsen v. Commissioner.

United States Tax Court.

Entered December 30, 1944.


Attorney(s) appearing for the Case

Conrad T. Hubner, Esq., 700 Mills Bldg., San Francisco, Calif., for the petitioners. Arthur L. Murray, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

The respondent determined a deficiency of $605.55 in the income tax of each of the petitioners for the year 1941.

The single issue is whether the gain realized from the disposition of the interest of the petitioner, N. Nielsen, in the partnership doing business as Vulcan Machine Company, constituted ordinary income or capital gain.

Findings of Fact

The facts were stipulated and as so stipulated are...

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