CLARKE v. COMMISSIONER

Docket No. 4464.

5 T.C.M. 11 (1946)

William A. Clarke v. Commissioner.

United States Tax Court.

Entered January 11, 1946.


Attorney(s) appearing for the Case

Henry D. O'Connor, Esq., 642 Real Estate Trust Bldg., Philadelphia 7, Pa., for the petitioner. William H. Best, Jr., Esq., for the respondent.


Memorandum Findings of Fact and Opinion

SMITH, Judge:

This proceeding is for the redetermination of deficiencies in income tax for the calendar years 1940 and 1941 in the respective amounts of $1,677.27 and $5,655.18. The petition alleges as follows:

(a) The Commissioner erred in disallowing the deduction for accrued interest on various obligations of the taxpayer, the taxpayer filing his income tax returns upon the accrual basis.

(b) The...

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