FEINGOLD v. COMMISSIONER

Docket No. 6992-65.

49 T.C. 461 (1968)

MAX FEINGOLD AND GERTRUDE FEINGOLD, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 7, 1968.


Attorney(s) appearing for the Case

Noah Seedman, for the petitioners.

Agatha J. Vorsanger, for the respondent.


SIMPSON, Judge:

The respondent determined deficiencies in the petitioners' income tax for the calendar year 1961 in the amount of $1,509.91 and for the calendar year 1962 of $3,937.45. The principal question in this case is whether an election by a small business corporation under subchapter S of the Internal Revenue Code of 19541 terminated by reason of its having derived more than 20 percent of its gross receipts from "rents....

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