KEENER v. COMMISSIONER

Docket No. 1755-71.

59 T.C. 302 (1972)

SETH E. KEENER, JR., AND JEANNE M. KEENER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 22, 1972.


Attorney(s) appearing for the Case

E. Jackson Boggs and Edwin A. Pennell, for the petitioners.

Robert J. Shilliday, Jr., for the respondent.


WITHEY, Judge:

Respondent determined a deficiency in petitioners' income tax for the taxable year 1967 in the amount of $3,050.46.

The issues presented for our consideration are:

(1) Whether payments made by petitioner's employer to petitioners during the taxable year 1967 represent a reimbursement for a loss sustained on the sale of petitioners' residence and, therefore, income to them under section 61(a), I.R.C. 1954, and

(2) Whether...

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