FREEDMAN v. COMMISSIONER

Docket No. 8613.

6 T.C.M. 414 (1947)

Harold D. Freedman v. Commissioner.

United States Tax Court.

Entered April 21, 1947.


Attorney(s) appearing for the Case

Joseph L. Jonick, C. P. A., and Emanuel A. Obstfeld, Esq., 535 Fifth Ave., New York 17, N. Y., for the petitioner. Thomas R. Charshee, Esq., for the respondent.


Memorandum Opinion

LEMIRE, Judge:

The Commissioner determined a deficiency of $4,609.10 in the petitioner's income tax for 1943. The primary issue is whether the Commissioner erred in disallowing a deduction for an expense which the petitioner claims that he "constructively paid" during the taxable year.

[The Facts]

The petitioner resides in New York City. He filed his individual return with the collector of internal revenue for...

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