CLARK v. COMMISSIONER

Docket No. 13686.

11 T.C. 672 (1948)

WILLIS W. CLARK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 25, 1948.


Attorney(s) appearing for the Case

David A. Gaskill, Esq., and William A. Polster, Esq., for the petitioner.

Howard M. Kohn, Esq., for the respondent.


The respondent has determined a deficiency of $24,287.58 in the petitioner's income and victory tax for 1943. The year 1942 is involved because of the forgiveness provisions of the Current Tax Payment Act of 1943.

The sole question in issue is whether the petitioner is taxable in 1942 on the entire amount of compensation which he received in that year from a corporation of which he was president and a principal stockholder, although during the taxable year he undertook...

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