PETIT v. COMMISSIONER

Docket No. 8839.

10 T.C. 1253 (1948)

WALLACE H. PETIT AND EULA J. PETIT, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 30, 1948.


Attorney(s) appearing for the Case

James P. Hill, Esq., for the petitioners.

Edward L. Potter, Esq., for the respondent.


This proceeding involves a deficiency in Federal income tax for the taxable year ended December 31, 1944, in the amount of $13,859.40, and a fraud penalty of $6,929.70.

The first question for decision is whether certain proceeds received by petitioner in connection with sales in 1944 which violated certain regulations of the Office of Price Administration are taxable income under section 22 (a) of the Internal Revenue Code. The remaining issue is whether petitioner...

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