JACOBS v. COMMISSIONER

Docket No. 40649.

21 T.C. 165 (1953)

S. NICHOLAS JACOBS AND DOLORES I. JACOBS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 30, 1953.


Attorney(s) appearing for the Case

Everett S. Layman, Esq., and Kenneth S. Carey, Esq., for the petitioners.

C. W. Nyquist, Esq., for the respondent.


Respondent determined a deficiency in income tax of the petitioners for the year 1948 in the amount of $42,109.63. Several of the adjustments made by respondent have been conceded by petitioners. One issue raised by the pleadings, respecting respondent's disallowance of a claimed deduction for attorney's fees in the amount of $1,000, has been resolved by agreement of the parties.

The questions remaining for our consideration are:

1. Whether the gain on a certain...

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