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REESE v. COMMISSIONER

Docket No. 42654.

13 T.C.M. 823 (1954)

T. C. Memo. 1954-134

Thomas E. Reese and Blanche S. Reese, husband and wife, v. Commissioner.

United States Tax Court.

Filed August 23, 1954.

Attorney(s) appearing for the Case

Lester I. Bowman, Esq., Union Trust Building, Petersburg, Va., for the petitioners. Ralph G. de Quevedo, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

JOHNSON, Judge:

This proceeding involves the following deficiencies in income tax and penalties:

  Year          Deficiency   5% Penalty

  1947 ......   $58,185.58    $2,909.28
  1948 ......    10,424.26       521.21

The issues are: (1) whether profit realized from sales of real estate is taxable as ordinary income or as capital gain; (2) whether certain bank deposits of cash and an amount...

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