DELP v. COMMISSIONER

Docket No. 5719.

5 T.C. 1351 (1945)

FRANK S. DELP, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 29, 1945.


Attorney(s) appearing for the Case

Walter W. McVay, Esq., for the petitioner.

Brooks Fullerton, Esq., for the respondent.


Petitioner contests the determination of a deficiency in his income tax for 1941 in the amount of $792.91. The only question in issue is whether the petitioner is taxable upon 5/24 of the net income of a business carried on under the name of S. Delp's Sons or upon 6/24, as determined by the respondent.

FINDINGS OF FACT.

The petitioner is an attorney at law and resident of Pittsburgh, Pennsylvania. He filed his income tax return for 1941 with the collector...

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