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SIC v. COMMISSIONER

Docket No. 12367.

10 T.C. 1096 (1948)

JOSEPH SIC, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 10, 1948.

Attorney(s) appearing for the Case

Philip G. Johnson, C. P. A., for the petitioner.

Frank M. Cavanaugh, Esq., for the respondent.

OPINION.

LEECH, Judge:

Respondent has determined a deficiency in income tax for the calendar year 1943 in the amount of $1,793.67. The question presented is whether the petitioner, as the result of the sale of a part of his farm property in 1942, incurred a net operating loss "attributable to the operation of a trade or business regularly carried on" by him within section 122 (d) (5) of the Internal Revenue...

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