JEFFERSON AUTO PARKING CO., INC. v. COMMISSIONER

Docket No. 85531.

22 T.C.M. 1341 (1963)

T.C. Memo. 1963-266

Jefferson Auto Parking Co., Inc. v. Commissioner.

United States Tax Court.

Filed September 27, 1963.


Attorney(s) appearing for the Case

Samuel L. Siegel, 375 Park Ave., New York, N. Y., for the petitioner. Robert A. Trevisani, for the respondent.


Memorandum Findings of Fact and Opinion

OPPER, Judge:

Respondent determined a deficiency of $17,964.32 in petitioner's income tax for the calendar year 1955. The issues are (1) whether deposits under a defaulted contract for the sale of real estate were received without restriction as payment by petitioner in 1955 rather than 1956 and, if so, (2) whether such payment was taxable as ordinary income.

Findings of Fact

Some of the facts are...

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