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MARCELLO v. COMMISSIONER

Docket No. 2650-62.

43 T.C. 168 (1964)

JOSEPH MARCELLO, JR., AND ANASTASIA MARCELLO, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 13, 1964.

Attorney(s) appearing for the Case

deQuincy V. Sutton, for the petitioners.

Robert S. Leigh, for the respondent.

DAWSON, Judge:

Respondent determined a deficiency in petitioners' income tax for the taxable year 1958 in the amount of $14,210.48 and a 5-percent addition to tax under the provisions of section 6653(a) of the Internal Revenue Code of 1954. Respondent disallowed all business expenses claimed by petitioners in the amount of $1,655 and increased petitioners' taxable income $26,666.66 by including in taxable income a gain on the sale of a capital asset. The adjustments...

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