WERNER v. COMMISSIONER

Docket No. 93609.

21 T.C.M. 1434 (1962)

T.C. Memo. 1962-269

Fred E. Werner and Juanita C. Werner v. Commissioner.

United States Tax Court.

Filed November 19, 1962.


Attorney(s) appearing for the Case

Guy A. Magruder, Jr., Esq., for the petitioners. Hugh C. McMahon, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

DAWSON, Judge:

The respondent determined a deficiency in the petitioners' income tax for the year ended December 31, 1959, in the amount of $523.22.

The only issue for decision is whether the amount realized upon the cancellation of unsecured debts owed to the corporate employer at the time petitioner's employment was terminated constituted ordinary income...

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