COVERDALE v. COMMISSIONER

Docket No. 3981.

4 T.C.M. 713 (1945)

William H. Coverdale v. Commissioner.

United States Tax Court.

Entered June 28, 1945.


Attorney(s) appearing for the Case

James C. Mulligan, Esq., 20 Exchange Place, New York 5, N. Y., for the petitioner. Ellyne Strickland, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

HILL, Judge:

This proceeding involves an income tax deficiency of $21,808.12 for the year 1940. Petitioner, an individual, duly filed his income tax return with the collector of internal revenue for the third district of New York and reported as a long-term capital gain the result of his dealings in Canadian money. Respondent determined the deficiency by treating the amount reported as ordinary income. Petitioner now...

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