KELLEY v. COMMISSIONER

Docket No. 67775.

19 T.C.M. 263 (1960)

T.C. Memo. 1960-52

David Howard Kelley v. Commissioner.

United States Tax Court.

Filed March 25, 1960.


Attorney(s) appearing for the Case

Franklin R. Davis, Esq., 6772 Hollywood Blvd., Hollywood, Calif., for the petitioner. John Schessler, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

Respondent determined a deficiency in the income tax of petitioner for the year 1953 in the amount of $3,263.94.

The sole issue is whether the unpaid balance of a note issued by petitioner in favor of National Associates, Inc. was forgiven in 1953 and constituted taxable income for that year.

Findings of Fact

Some of the facts have been stipulated and, as stipulated, they are incorporated herein by...

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