PHILLIPS v. COMMISSIONER

Docket No. 43645.

13 T.C.M. 643 (1954)

T. C. Memo. 1954-93

Bernice R. Phillips v. Commissioner.

United States Tax Court.

Filed June 30, 1954.


Attorney(s) appearing for the Case

Sanford Becker, C. P. A., 11 West 42nd Street, New York, N. Y., for the petitioner. S. Jarvin Levison, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

HARRON, Judge:

The Commissioner determined a deficiency in income tax for 1947 in the amount of $1,812.37. The only issue for decision is whether the loss sustained upon the sale of residential property, together with furnishings, is a personal loss and nondeductible, or a loss incurred in a trade or business, or in a transaction entered into for profit and deductible under section 23(e), I. R. C. If it is determined...

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