BROADFOOT v. COMMISSIONER

Docket No. 36067.

11 T.C.M. 878 (1952)

Hibbard E. Broadfoot and Helen C. Broadfoot v. Commissioner.

United States Tax Court.

Entered August 20, 1952.


Attorney(s) appearing for the Case

Charles A. Scharf, Esq., for the petitioners. S. Jarvin Levison, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

The Commissioner has determined a deficiency in petitioners' income tax of $908.46 for the year 1946. The deficiency is due to two adjustments which the Commissioner made to the net income reported by petitioners on their return. These adjustments are explained in the deficiency notice as follows:

"(a) and (b) The deduction of $3,934.74 which amount is included in the miscellaneous deduction of $5,472.24, for advances...

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