MIDDLEBROOK v. COMMISSIONER

Docket No. 13879.

13 T.C. 385 (1949)

JOSEPH MIDDLEBROOK, JR., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 27, 1949.


Attorney(s) appearing for the Case

J. G. Houston, Esq., and John G. Kish, Esq., for the petitioner.

Hobby H. McCall, Esq., for the respondent.


Respondent determined deficiencies in petitioner's income tax for the calendar years 1941, 1944, and 1945 in the respective amounts of $18,894.82, $12,507.94, and $8,703.28, and in the petitioner's income and victory tax for the year 1943 in the amount of $10,773.58. The year 1942 is involved, due to the forgiveness feature of the Current Tax Payment Act of 1943.

The deficiencies are primarily due to the determination by the respondent that the portion of the earnings...

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