ENGLAND v. COMMISSIONER

Docket No. 69416.

37 T.C. 1150 (1962)

J. H. ENGLAND, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 27, 1962.


Attorney(s) appearing for the Case

James Powers, Esq., for the petitioner.

James Q. Smith, Esq., for the respondent.


PIERCE, Judge:

The respondent determined a deficiency of $6,393.19 in the income tax of petitioner for the calendar year 1954. The sole issue for decision is, whether the amount of $15,800 which petitioner paid to his former wife as "rental," pursuant to the terms of a written lease covering certain farm property, is deductible by him as an expense of his farming operations; or whether said amount constituted in reality, part of a property settlement between...

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