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YOUNG v. COMMISSIONER

Docket No. 58131.

20 T.C.M. 150 (1961)

T.C. Memo. 1961-33

E. Merl Young and Lauretta W. Young v. Commissioner.

United States Tax Court.

Filed February 9, 1961.

Attorney(s) appearing for the Case

Eugene Meacham, Esq., 824 Connecticut Ave., N. W., Washington, D. C., Fred R. Tansill, Esq., and Louis Hoppe, Esq., for the petitioners. Henry C. Stockell, Jr., Esq., and Lee C. Smith, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined deficiencies in income tax for the taxable years 1949, 1950, and 1951 in the amounts of $6,108.10, $2,558.84, and $204.78, respectively. Based upon alternative contentions, he has made claims for increases in the deficiencies for 1950 and 1951 under section 272(e) of the 1939 Code.

The general issue is whether amounts received in 1949, 1950, and 1951 by E. Merl Young from two corporations...

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