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BRADY v. COMMISSIONER

Docket No. 71280.

35 T.C. 311 (1960)

C. TED BRADY AND AGNES J. BRADY, HIS WIFE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 22, 1960.

Attorney(s) appearing for the Case

Wayne Calhoun Booth, Esq., for the petitioners.

James D. Webb, III, Esq., for the respondent.

OPINION.

MURDOCK, Judge:

The Commissioner determined deficiencies of $8,767.22 and $51,776.54 in income tax of the petitioners for the years 1952 and 1954. One of the adjustments which he made for 1954 was to add $126,617.44 to income with the following explanation:

(a) It has been determined that you realized a long term capital gain in 1954 of $253,234.88 as the result of the transfer by you of 126...

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