POTTER v. COMMISSIONER

Docket Nos. 7473, 7474.

5 T.C.M. 116 (1946)

Paul M. Potter, Lula W. Potter v. Commissioner. Frederick H. Rayfield, Mildred S. Rayfield v. Commissioner.

United States Tax Court.

Entered February 28, 1946.


Attorney(s) appearing for the Case

Herbert Johnson, Esq., 710 Rhodes-Haverty Bldg., Atlanta 3, Ga., for the petitioners. F. L. Van Haaften, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

OPPER, Judge:

These proceedings are brought for a redetermination of deficiencies in tax as follows:

       Petitioners       Year  Income Tax

  Paul M. Potter ......  1940   $2,961.92
  Lula W. Potter
  Frederick H. Rayfield  1940    3,063.52
  Mildred S. Rayfield

The question presented is whether petitioners realized taxable income in 1940 on the receipt of notes from Potter & Rayfield...

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