ALLEN v. COMMISSIONER

Docket No. 31798.

22 T.C. 70 (1954)

W. O. ALLEN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 20, 1954.


Attorney(s) appearing for the Case

Graham Loving, Jr., Esq., and L. Karlton Mosteller, Esq., for the petitioner.

John P. Higgins, Esq., for the respondent.


The respondent determined deficiencies in the income tax of petitioner in the amounts of $3,362.06 for the year 1944 and $1,038.03 for the year 1945.

Various issues raised by the pleadings are no longer in controversy by reason of concessions made at the trial. Two issues remain:

(1) To what extent may a loss from the operation of a business in 1946 be treated as a community loss in determining the net operating loss of the husband for purposes of carry-back...

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