HAMEL v. COMMISSIONER

Docket Nos. 77713, 77714.

19 T.C.M. 635 (1960)

T.C. Memo. 1960-121

Jack Hamel v. Commissioner. Jack Hamel and Jane Hamel v. Commissioner.

United States Tax Court.

Filed June 8, 1960.


Attorney(s) appearing for the Case

Fred S. Ball, Jr., Esq., First National Bank Building, Montgomery, Ala., for the petitioners. Homer F. Benson, Esq., for the respondent.


Memorandum Opinion

PIERCE, Judge:

The Commissioner determined deficiencies in income tax for the years 1956 and 1957 in the respective amounts of $970.67 and $2,327.21. The cases were consolidated for trial.

The sole issue for decision is whether the net increases in petitioner's credit balance of an automobile dealer's reserve account, composed only of that portion of a finance company's charges...

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