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KAHLER v. COMMISSIONER

Docket No. 27517.

18 T.C. 31 (1952)

CHARLES F. KAHLER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 4, 1952.

Attorney(s) appearing for the Case

Walter R. Brown, Esq., for the petitioner.

Thomas A. Steele, Jr., Esq., for the respondent.

The respondent determined a deficiency in income tax for the year 1946 in the amount of $2,073.30. The petitioner has conceded the correctness of some of the adjustments made in determining the deficiency. The sole issue is whether petitioner realized income in 1946 when his employer paid him for commissions earned during that year by a check dated December 31, 1946, and delivered it to him after banking hours.

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