FITZGERALD v. COMMISSIONER

Docket No. 52539.

15 T.C.M. 1450 (1956)

T.C. Memo. 1956-280

Raymond Fitzgerald and Manor M. Fitzgerald, Husband and Wife v. Commissioner.

United States Tax Court.

Filed December 27, 1956.


Attorney(s) appearing for the Case

Raymond Fitzgerald, 4034 Third Avenue N., St. Petersburg, Fla., for the petitioners. Hugh G. Isley, Jr., Esq., for the respondent.


Memorandum Findings of Fact and Opinion

TURNER, Judge:

The respondent determined deficiencies of $183.80, $254.48 and $256.16 in income tax against the petitioners for the years 1950, 1951 and 1952, respectively. The questions for decision are (1) whether the activities of Raymond Fitzgerald in purchasing, owning and selling corporate stocks in the years herein constituted the carrying on of a trade or business and, as a consequence, the expenses in connection...

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