BAZLEY v. COMMISSIONER

Docket Nos. 1520, 1521.

4 T.C. 897 (1945)

ALICE H. BAZLEY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. J. ROBERT BAZLEY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 28, 1945.


Attorney(s) appearing for the Case

Frederick E. S. Morrison, Esq., and Calvin H. Rankin, Esq., for the petitioners.

W. J. McFarland, Esq., for the respondent.


By these consolidated proceedings petitioners challenge respondent's determination of deficiencies in their income tax for the year 1939 as follows: J. Robert Bazley, $214,170.52; and Alice H. Bazley, his wife, $35,734.49. J. Robert Bazley will sometimes hereinafter be referred to for convenience as petitioner.

The primary question involved is whether the petitioners are taxable, as charged by respondent, with having received ordinary income during the taxable year...

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