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CAMPBELL v. COMMISSIONER

Docket No. 56121.

20 T.C.M. 825 (1961)

T.C. Memo. 1961-166

S. J. Campbell and Ileen B. Campbell v. Commissioner.

United States Tax Court.

Filed June 8, 1961.

Attorney(s) appearing for the Case

B. W. Flinn, C. P. A., City Hall Bldg., Rockford, Ill., and Karl C. Williams, Esq., for the petitioners. Walter T. Hart, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined income tax deficiencies for 1949 and 1950 in the amounts of $4,588.82 and $9,602.81, respectively. The first question is whether amounts paid by a corporation to cover expenses incurred by one of the petitioners represented income to petitioners rather than ordinary and necessary business expenses of the corporation. The second question is whether gains from sales of horses were capital gains.<...

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