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ENGLER v. COMMISSIONER

Docket Nos. 26657 and 26658.

11 T.C.M. 40 (1952)

J. Fred Engler v. Commissioner. Lenore S. Engler v. Commissioner.

United States Tax Court.

Entered January 21, 1952.

Attorney(s) appearing for the Case

Wentworth T. Durant, Esq., and S. L. Mayo, Esq., 625 Republic Bk. Bldg., Dallas, Tex., for the petitioners. J. Frost Walker, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined deficiencies in income tax of $2,707.18 for 1944 and $1,840.51 for 1945 against J. Fred Engler, and deficiencies of $2,707.18 for 1944 and $1,729.93 for 1945 against Lenore S. Engler. The only issues for decision are whether the Commissioner erred in determining that $9,848.94 received by Engler in 1945 was earned commissions or otherwise taxable income in 1944 or 1945 and, in the alternative, whether...

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