R. A. STEWART & CO. v. COMMISSIONER

Docket No. 2149-69.

57 T.C. 122 (1971)

R. A. STEWART & CO., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 26, 1971.


Attorney(s) appearing for the Case

Sidney Meyers, for the petitioner.

Ronald A. Wagenheim, for the respondent.


QUEALY, Judge:

The respondent determined deficiencies in the Federal income tax due from the petitioner as follows:

   Year                     Deficiency

   1965 ------------------- $6,212.94
   1966 -------------------  7,458.82

Concessions having been made, the only issue presented for decision is whether petitioner should recognize gain in 1965 on account of payments made to it by the City of New York for the appropriation...

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