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BEELER v. COMMISSIONER

Docket No. 5259-63.

25 T.C.M. 659 (1966)

T.C. Memo. 1966-130

Charles W. Beeler and Ann Beeler v. Commissioner.

United States Tax Court.

Filed June 16, 1966.

Attorney(s) appearing for the Case

Conrad T. Hubner, 68 Post St., San Francisco, Calif., for the petitioners. Roger A. Pott, for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency in petitioners' 1959 income tax in the amount of $260,005.16 plus an addition to tax in the amount of $13,000.26 pursuant to Section 6653, Internal Revenue Code of 1954. The only matters presently in issue are (1) whether petitioner Charles W. Beeler received income in the amount of $325,000 in 1959 in respect of a certain note which he acquired in 1957 and sold in 1958; and (2) whether...

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