Howey v. Commissioner

Mary Grace Howey v. Commissioner.

Howey v. Commissioner

Docket No. 39712.

United States Tax Court

T.C. Memo 1954-19; 1954 Tax Ct. Memo LEXIS 220; 13 T.C.M. (CCH) 399; T.C.M. (RIA) 54125;

April 30, 1954, Filed

Robert Ash, Esq., and Carl F. Bauersfeld, Esq., for the petitioner. Newman A. Townsend, Jr., Esq., for the respondent.

OPPER

Memorandum Findings of Fact and Opinion

OPPER, Judge: Respondent determined deficiencies in income tax against petitioner as follows:

Year

Deficiency

1947

$14,475.79

1948

10,137.11

At the trial, petitioner moved for summary judgment on the pleadings as to the year 1947 upon the…