WILLCOX v. COMMISSIONER

Docket No. 37382.

20 T.C. 305 (1953)

WESTMORE WILLCOX AND ESTHER J. WILLCOX, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 8, 1953.


Attorney(s) appearing for the Case

James E. Bennet, Jr., Esq., for the petitioners.

S. Jarvin Levison, Esq., for the respondent.


The Commissioner determined a deficiency of $2,230.39 in the income tax of the petitioners for 1946. The only issue for decision is whether a loss sustained upon the sale of 146 East End Avenue, New York, is a loss from a transaction entered into for profit or is a nondeductible loss because it was from the sale of a personal residence.

FINDINGS OF FACT.

The petitioners, husband and wife, resided at 142 East End Avenue, New York, New York, and filed a joint...

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