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LOWE v. COMMISSIONER

Docket No. 4745-62.

44 T.C. 363 (1965)

ALVIN B. LOWE AND RUTH LOWE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 11, 1965.

Attorney(s) appearing for the Case

Thomas L. Wolfe, for the petitioners.

Kenneth G. Anderson, for the respondent.

DAWSON, Judge:1

Respondent determined a deficiency in petitioners' income tax for the taxable year ended December 31, 1958, in the amount of $14,364.84.

The deficiency is based upon respondent's determinations that $22,500 retained by Alvin B. Lowe on the reacquisition of stock in 1958 represents ordinary income to him and that certain management expenses are not deductible as ordinary and necessary business expenses. The...

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