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ESTATE OF THORESON v. COMMISSIONER

Docket No. 35117.

23 T.C. 462 (1954)

ESTATE OF ALFRED B. THORESON, DECEASED, LILLIAN THORESON, EXECUTRIX, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 10, 1954.

Attorney(s) appearing for the Case

V. Downing Edwards, Esq., for the petitioner.

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

Respondent determined a deficiency in income tax of Alfred B. Thoreson, deceased, in the amount of $1,102.29 for the taxable year 1946.

The sole question for decision is whether $4,800 received by Alfred B. Thoreson in 1946 constituted "back pay" of $1,200 for each of the years 1932, 1933, 1934, and 1935 within the meaning of section 107 (d) (2) (A) (iv), Internal Revenue Code of 1939.

The parties hereto have stipulated...

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