BURNS v. COMMISSIONER

Docket No. 25314.

21 T.C. 857 (1954)

JAY BURNS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 9, 1954.


Attorney(s) appearing for the Case

Alex P. Gaines, Esq., and John E. Simpson, Esq., for the petitioner.

Thomas C. Cravens, Jr., Esq., for the respondent.


Respondent determined deficiencies in income tax against petitioner for the calendar years 1944, 1945, and 1947 in the respective amounts of $5,479.86, $3,616.54, and $7,942.28. Petitioner also claims overpayments in income tax for the years 1944 and 1945 in the respective amounts of $477.57 and $1,277.97, by virtue of an alleged operating loss carry-back from the year 1946.

The questions are (1) whether the respondent erred in determining that losses sustained by...

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