SMITH v. COMMISSIONER

Docket No. 10833.

9 T.C. 1150 (1947)

NORTON L. SMITH AND JEAN T. SMITH, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 18, 1947.


Attorney(s) appearing for the Case

Eugene L. Lora, Esq., for the petitioners.

Neil D. McCarthy, Esq., for the respondent.


Respondent determined a deficiency in petitioner's income and victory tax for the year ended December 31, 1943, in the amount of $884.07. The deficiency results from respondent's disallowance of certain deductions claimed for farm losses in 1942 and 1943. The question for determination is whether such losses are deductible and that question in turn depends on whether the farm was operated for profit. Due to the forgiveness feature applicable to 1942 and 1943, the deficiency...

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