WALLENDAL v. COMMISSIONER

Docket No. 62182.

31 T.C. 1249 (1959)

ROBERT J. WALLENDAL AND MARION G. WALLENDAL, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 31, 1959.


Attorney(s) appearing for the Case

W. A. Wagner, Esq., for the petitioners.

Thomas J. Donnelly, Jr., Esq., for the respondent.


PIERCE, Judge:

Respondent determined a deficiency of $206.32 in petitioners' income tax for the calendar year 1953.

The issues presented are:

(1) Whether the amount of $499.06 paid by the principal petitioner as interest on the unpaid balance of the contract price for his purchase of a share in a business partnership, is an expense attributable to a "trade or business carried on by the taxpayer" within the meaning of section 22(n) (1) of the...

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