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TOWNEND v. COMMISSIONER

Docket No. 51448.

27 T.C. 99 (1956)

MAE E. TOWNEND, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 22, 1956.

Attorney(s) appearing for the Case

Frank Townend, Esq., for the petitioner.

Jules I. Whitman, Esq., for the respondent.

Respondent has determined deficiencies in the income tax of petitioner for the taxable years 1946 and 1947 in the respective amounts of $2,014.13 and $3,383.34. Only the year 1946 is in issue in this proceeding. The issues are as follows:

(1) Did respondent err in determining that a sale in 1945 by petitioner of real property was not attributable to the operation of a trade or business regularly carried on by her, and hence...

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