DEAN v. COMMISSIONER

Docket No. 13301.

10 T.C. 672 (1948)

JAMES NEWTON DEAN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 21, 1948.


Attorney(s) appearing for the Case

Albert W. Fox, Esq., for the petitioner.

E. M. Woolf, Esq., for the respondent.


Respondent determined a deficiency in the income tax of petitioner for the year 1944 in the amount of $2,760.41. The sole question is, Does the amount of $13,045.32 paid by Engineering and Research Corporation to petitioner on April 5, 1944, constitute "back pay" within the meaning of section 107 (d) (2) of the Internal Revenue Code?

FINDINGS OF FACT.

Petitioner is an individual, who resided in Hyattsville, Maryland, during the years 1942, 1943, and 1944...

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