EMERY v. COMMISSIONER

Docket No. 6106.

8 T.C. 979 (1947)

THOMAS EMERY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 7, 1947.


Attorney(s) appearing for the Case

C. Walter Randall, Jr., Esq., for the petitioner.

William H. Best, Jr., Esq., for the respondent.


OPINION.

JOHNSON, Judge:

The Commissioner determined a deficiency of $983.88 in petitioner's income tax for 1941 by adjustments not in controversy. In an amended petition petitioner asserts that he erroneously reported gains and losses from exchanges of bonds of the city of Philadelphia for refunding bonds of like amount issued by the city, and contends that the exchanges were nontaxable transactions because the old and new certificates represented...

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