HEUER v. COMMISSIONER

Docket No. 65538.

32 T.C. 947 (1959)

WILLIAM L. HEUER, JR., AND LUCILLE M. HEUER, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 23, 1959.


Attorney(s) appearing for the Case

Elwood R. Clay, Esq., and Louis J. Dutrey, Esq., for the petitioners.

J. L. Bailey, Esq., for the respondent.


ATKINS, Judge:

Respondent determined deficiencies in income tax of petitioners for the years 1953 and 1954 in the respective amounts of $547.64 and $423.20, and for the year 1953 determined additions to tax under section 294(d)(1)(A) and section 294(d)(2) of the Internal Revenue Code of 1939, in the respective amounts of $184.32 and $122.88.

The issue presented is whether the petitioner, a ship pilot, is entitled to deduct as ordinary and necessary...

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