MANNING v. COMMISSIONER

Docket No. 5472.

8 T.C. 537 (1947)

ASHLEY MANNING, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 12, 1947.


Attorney(s) appearing for the Case

A. Calder Mackay, Esq., and Adam Y. Bennion, Esq., for the petitioner.

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


This proceeding involves a deficiency in income tax for the calendar year 1941 in the amount of $12,514.01. In determining this deficiency the respondent made two adjustments to the net income as disclosed by petitioner's return for the year 1941, only one of which adjustments, namely, "(a) Income from business $22,113.09," is contested. In a statement attached to the deficiency notice the respondent explained this adjustment as follows:

(a) Net income from business...

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