MILLIKEN v. COMMISSIONER

Docket No. 19402.

15 T.C. 243 (1950)

SETH M. MILLIKEN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 21, 1950.


Attorney(s) appearing for the Case

A. A. Patterson, Esq., for the petitioner.

William E. Murray, Esq., for the respondent.


The Commissioner determined a deficiency of $24,435.23 in income tax for 1943. The petitioner alleges that the Commissioner erroneously included in income for 1942 the entire $27,848.24 received from Cotwool Manufacturing Corporation which the petitioner reported as a long term capital gain and failed to allow as an ordinary loss deduction, $33,411.29 paid by the petitioner as a transferee during 1942, representing his share of Federal income tax deficiencies determined against...

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