HODOUS v. COMMISSIONER

Docket No. 16670.

14 T.C. 1301 (1950)

FRANK HODOUS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 28, 1950.


Attorney(s) appearing for the Case

James R. Felt, Esq., for the petitioner.

Douglas L. Barnes, Esq., for the respondent.


Respondent determined deficiencies in petitioner's income tax liability for the taxable years 1943, 1944, and 1945 in the respective amounts of $722.92, $738.81, and $2,357.76. These deficiencies involve three issues raised by the pleading:

(1) Whether payments received by petitioner in the above years in the respective amounts of $4,478.20, $5,602.10, and $6,545.56 constitute compensation for services and thus are taxable as ordinary income as determined by respondent...

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