SAGE v. COMMISSIONER

Docket No. 22349.

15 T.C. 299 (1950)

HENRY E. SAGE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 25, 1950.


Attorney(s) appearing for the Case

Harold E. Mitchell, Esq., for the petitioner.

W. C. W. Haynes, Esq., for the respondent.


The Commissioner determined a deficiency of $17,915.08 in income tax for 1943. The errors assigned are the disallowance of a deduction of $19,452.46 for 1942 representing a net operating loss carry-over from 1941 and the disallowance of an earned income credit with respect to income from the Modern Tools Co., a partnership, for the year 1942, or for that portion of the year prior to the petitioner's entry into the Army.

FINDINGS OF FACT.

The petitioner filed...

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