Price v. Commissioner

James S. Price and Mae D. Price v. Commissioner.

Price v. Commissioner

Docket No. 94396.

United States Tax Court

T.C. Memo 1963-172; 1963 Tax Ct. Memo LEXIS 173; 22 T.C.M. (CCH) 818; T.C.M. (RIA) 63172;

June 20, 1963

Frederic S. Kramer, for the respondent.

MULRONEY

Memorandum Opinion

MULRONEY, Judge: The respondent determined a deficiency in petitioners' 1958 income tax in the amount of $1,240.98. The issue is whether petitioner James S. Price, a cash basis taxpayer, constructively received an item of $5,000 income in 1958.

All of the facts are stipulated and are found accordingly.

James S. Price,…