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LeVAN v. COMMISSIONER

Docket No. 17978.

10 T.C.M. 1219 (1951)

James Buford LeVan v. Commissioner.

United States Tax Court.

Entered December 26, 1951.

Attorney(s) appearing for the Case

Fred M. Williams, Jr., Esq., Chattanooga Bank Bldg., Chattanooga, Tenn., and Harold A. Kertz, Esq., for the petitioner. Percy C. Young, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

LEECH, Judge:

This proceeding involves deficiencies in income tax for the calendar years 1941, 1943 and 1944, in the respective amounts of $6,335.62, $107,955.10 and $25,356.74. Due to the forgiveness feature of the Current Tax Payment Act of 1943, the year 1942 is also involved.

The issues are:

1. Whether, during the taxable periods involved, petitioner and his wife, Florence

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