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TERRY v. COMMISSIONER

Docket No. 19946.

8 T.C.M. 868 (1949)

Jesse L. Terry and Kathleen N. Terry v. Commissioner.

United States Tax Court.

Entered September 22, 1949.

Attorney(s) appearing for the Case

William H. Hall, Esq., for the petitioners. Stanley W. Herzfeld, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

OPPER, Judge:

By this proceeding petitioners challenge respondent's determination of a deficiency in income and victory tax of $23,405.02 for the year 1943. The year 1942 is involved because of the Current Tax Payment Act. The only question is whether $60,000 received in 1942 as compensation for personal services is subject to apportionment under section 107, Internal Revenue Code.

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