HALL v. COMMISSIONER

Docket 29345.

19 T.C. 445 (1952)

CAROL F. HALL AND ISABEL M. HALL, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 11, 1952.


Attorney(s) appearing for the Case

George E. Cleary, Esq., and George Stinson, Esq., for the petitioners.

Paul M. Stewart, Jr., Esq., for the respondent.


Respondent determined a deficiency in income tax for the calendar year 1947 in the amount of $2,906.29. Petitioners, husband and wife, filed a joint return for 1947 with the collector of internal revenue, Customhouse, New York, New York. Petitioner Carol F. Hall is a member of the partnership of Touche, Niven & Co., public accountants and auditors. The partnership's return of income, filed for its fiscal year ended September 30, 1947, reported an amount as ordinary income...

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