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CHURCH'S ENGLISH SHOES, LTD. v. COMMISSIONER

Docket No. 43028.

24 T.C. 56 (1955)

CHURCH'S ENGLISH SHOES, LTD., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 21, 1955.

Attorney(s) appearing for the Case

Paul V. Wolfe, Esq., for the petitioner.

James J. Quinn, Esq., for the respondent.

OPINION.

HARRON, Judge:

The Commissioner determined a deficiency in income tax of $577.72 for the fiscal year ended June 30, 1947. The only issue to be decided is whether the petitioner realized ordinary gain in the amount of $2,063.30 in connection with the discharge of an indebtedness to Church & Company, Ltd., of England under the facts set forth hereinafter. The sum of $2,063.30 is the difference between...

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