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WOODWARD v. COMMISSIONER

Docket No. 3573-66.

50 T.C. 982 (1968)

WALTER L. WOODWARD AND BERNICE A. WOODWARD, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 30, 1968.

Attorney(s) appearing for the Case

Francis J. Butler, for the petitioners.

Gary C. Randall, for the respondent.

BRUCE, Judge:

Respondent determined deficiencies in income tax of the petitioners in the amounts of $3,296.17 and $325.94 for 1963 and 1964, respectively. Two issues are presented for decision, (1) whether the petitioners may apply section 1301 of the Internal Revenue Code of 1954, as effective in 1963, in computing the tax with respect to certain earnings of Walter L. Woodward received in 1963, and (2) whether respondent erred in the disallowance of certain...

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