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SMITH v. COMMISSIONER

Docket No. 27569.

17 T.C. 135 (1951)

WELDON D. SMITH, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated July 31, 1951.

Attorney(s) appearing for the Case

Robert J. Lansdowne, Esq., for the petitioner.

Sheldon V. Ekman, Esq., for the respondent.

The respondent determined a deficiency in petitioner's income tax for the year 1945 in the amount of $69,184.95. The issues to be decided are: (1) whether $212,000 paid petitioner by a former employer during 1945 constituted back pay subject to the provisions of section 107 (d) of the Internal Revenue Code; and (2) whether $38,220 represented a debt owed petitioner, whether it became worthless in 1945, and whether, if it was a debt...

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