SPRAY WATER POWER AND LAND COMPANY v. COMMISSIONER

Docket No. 73024.

20 T.C.M. 353 (1961)

T.C. Memo. 1961-73

Spray Water Power and Land Company v. Commissioner.

United States Tax Court.

Filed March 16, 1961.


Attorney(s) appearing for the Case

Wm. H. Westphal, Esq., Southeastern Bldg., Greensboro, N. C., and Wm. J. Adams, Jo., Esq., for the petitioner. Harvey S. Jackson, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

The Commissioner determined a deficiency in the income tax of petitioner in the amount of $6,945.71 for the taxable period August 1, 1953 to March 31, 1954. The sole issue for decision is whether an amount received by petitioner was ordinary income or, as claimed by petitioner, not taxable at all.

Findings of Fact

Some of the facts have been stipulated and are incorporated herein...

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