TYRRELL v. COMMISSIONER

Docket No. 86267.

21 T.C.M. 292 (1962)

T.C. Memo. 1962-53

James L. Tyrrell and Julia C. Tyrrell v. Commissioner.

United States Tax Court.

Filed March 15, 1962.


Attorney(s) appearing for the Case

Paul A. Weick, Esq., Flatiron Bldg., Akron, Ohio, for the petitioners. Thomas J. Moroney, Jr., Esq., for the respondent.


Memorandum Findings of Fact and Opinion

FAY, Judge:

The Commissioner determined deficiencies in the petitioners' income taxes, as follows:

  Year                  Amount

  1949 .............  $ 2,749.16
  1952 .............   17,761.17
  1953 .............    2,477.80
  1954 .............    2,477.58

Most of the issues have been conceded by the petitioners. The only issue for decision is what portion of sums received under an...

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