CARRINGTON v. COMMISSIONER

Docket Nos. 13281 and 15365.

7 T.C.M. 162 (1948)

Campbell Carrington v. Commissioner.

United States Tax Court.

Entered March 30, 1948.


Attorney(s) appearing for the Case

Max Herzfeld, Esq., and David Schnitzer, C. P. A., 270 Broadway, New York, N. Y., for the petitioner. R. O. Carlsen, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

OPPER, Judge:

These proceedings were brought for a redetermination of deficiencies of $1,348.95 and $1,649.95 for the taxable years 1943 and 1944, respectively.

The sole question involved is whether receipt by petitioner of $8,000 in each of the respective years constituted payment to petitioner of compensation for personal services or proceeds from the sale of stock in a prior year.

Findings of Fact...

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