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THERIOT v. COMMISSIONER

Docket No. 24984.

15 T.C. 912 (1950)

IRENE NUNNERY THERIOT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 21, 1950.

Attorney(s) appearing for the Case

John Y. Merrell, Esq., and Manuel W. Hickey, Esq., for the petitioner.

J. Frost Walker, Esq., for the respondent.

The Commissioner determined a deficiency in the petitioner's income tax liability for the taxable year 1943 in the amount $1,810.56, and a deficiency in the petitioner's income tax liability for the taxable year 1945 in the amount $17,137.33.

The issue in this proceeding is whether the petitioner should have reported her income for the years in question on the calendar year basis or on a fiscal year basis. Other adjustments in the petitioner's

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