DAVIS v. COMMISSIONER

Docket No. 51509.

26 T.C. 49 (1956)

HERBERT DAVIS AND GEORGIA DAVIS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 10, 1956.


Attorney(s) appearing for the Case

Clyde W. Key, Esq., for the petitioners.

Herman Wolff, Jr., Esq., for the respondent.


The respondent determined deficiencies in income taxes of petitioners for the taxable years 1948, 1949, and 1950, in the amounts of $8,691.08, $10,356.79, and $9,391.64, respectively.

The issues presented are: (1) Whether payments made by petitioner in excess of $3,600 per year under a lease arrangement with his father were deductible as rent under section 23 (a) (1) (A); (2) whether dues payments made by petitioner to a liquor dealers' association were ordinary and...

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