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HORTON v. COMMISSIONER

Docket Nos. 4206, 8534.

7 T.C. 957 (1946)

HIRAM T. HORTON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 14, 1946.

Attorney(s) appearing for the Case

Dana Latham, Esq., and Austin H. Peck, Jr., Esq., for the petitioner.

B. M. Coon, Esq., for the respondent.

This matter is before this Court to procure redetermination of deficiencies declared by the Commissioner for the years 1940 and 1941 in the respective amounts of $8,571.16 and $4,022.64. The deficiencies were occasioned by the refusal of the Commissioner to permit the taxpayer to exclude from his income percentages of net profit paid to the owner of a mining concession in Mexico which was being operated during those years by the taxpayer...

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