ROBERTSON v. COMMISSIONER

Docket No. 4187.

6 T.C. 1060 (1946)

JULIAN ROBERTSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 14, 1946.


Attorney(s) appearing for the Case

W. H. Holderness, Esq., for the petitioner.

Elmer L. Corbin, Esq., for the respondent.


The Commissioner determined a deficiency of $8,052.93 in income tax for the year 1941. The petitioner assails the inclusion in his taxable income of $12,500 paid in 1941 to the American Trust Co., trustee, pursuant to the provisions of an employment contract and trust agreement dated November 13, 1941.

FINDINGS OF FACT.

The petitioner is a resident of Salisbury, North Carolina. He filed his 1941 Federal income tax return on the cash basis with the collector...

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