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PERRY v. COMMISSIONER

Docket No. 41247.

22 T.C. 968 (1954)

EARL V. PERRY AND ETHEL M. PERRY, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 23, 1954.

Attorney(s) appearing for the Case

Darrow A. Dutcher, Esq., for the petitioners.

Paul D. Lagomarcino, Esq., for the respondent.

The Commissioner has determined a deficiency of $4,817.60 in petitioners' income tax for the calendar year 1949. The deficiency results from adjustments to petitioners' reported net income which were explained in the deficiency notice as follows:

(a) Your cancellation of an obligation [$20,000] owed you by the Perry Flower Shops, Inc. an existing corporation which you control, is held not to constitute an allowable deduction...

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