THOMPSON v. COMMISSIONER

Docket No. 32091.

18 T.C. 742 (1952)

THOMAS THOMPSON AND AGNES D. THOMPSON, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated July 11, 1952.


Attorney(s) appearing for the Case

Nathan Kosseff, C. P. A., for the petitioners.

Robert R. Blasi, Esq., for the respondent.


The Commissioner determined a deficiency of $18,503.88 in the income tax of the petitioners for 1946. The only issue for decision is whether an amount which Thomas received in 1946 is taxable under section 107 (d) (1).

FINDINGS OF FACT.

The petitioners, husband and wife, filed their return for 1946 with the collector of internal revenue for the district of Virginia.

Thomas was employed by Virginia Shoe Company...

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