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PRATT v. COMMISSIONER

Docket No. 490.

3 T.C.M. 423 (1944)

Charles H. Pratt and Helen A. Pratt v. Commissioner.

United States Tax Court.

Entered May 6, 1944.

Attorney(s) appearing for the Case

Eldridge Hart, Esq., Winter Park, Fla., for the petitioners. E. M. Woolf, Esq., for the respondent.

Findings of Fact and Memorandum Opinion

STERNHAGEN, Judge:

The Commissioner determined deficiencies of $714.23 and $992.12 in petitioners' income tax for 1940 and 1941, respectively. As to both years, a deduction for loss was disallowed on the ground that the sale had been completed in 1939; and for 1940 a deduction was disallowed on the ground that trustees' fees were not ordinary and necessary expenses. A claim was made in an amended petition for a deduction...

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