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BAILEY v. COMMISSIONER

Docket No. 22972.

9 T.C.M. 850 (1950)

William M. Bailey v. Commissioner.

United States Tax Court.

Entered October 10, 1950.

Attorney(s) appearing for the Case

William Wallace Booth, Esq., and Sidney B. Gambill, Esq., for the petitioner. Kalman A. Goldring, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

OPPER, Judge:

Petitioner seeks redetermination of a deficiency of $1,467.57 in income tax for 1946. Some adjustments are not contested. The only question is whether $3,533.40 which petitioner received from William M. Bailey Company, the petitioner in a related proceeding in Docket No. 22615, is taxable in full or as a long-term capital gain.

The case was heard on a stipulation of facts and other evidence.<...

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