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HALEY v. COMMISSIONER

Docket No. 28002.

16 T.C. 1462 (1951)

D. G. HALEY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 29, 1951.

Attorney(s) appearing for the Case

Henry Ravenel, Esq., and Lawrence A. Baker, Esq., for the petitioner.

Percy C. Young, Esq., for the respondent.

The Commissioner determined deficiencies in the income tax of the petitioner of $2,658.29 for 1943 and $3,690.55 for 1947. The issues for decision are whether section 107 (a) applies to the $7,500 which the petitioner received from his wife in 1943 and to $26,821.43 which the petitioner received from Clearwater Bay Company in 1947. The parties have agreed to dispose of other issues in the settlement under Rule 50.

FINDINGS...

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