Levinson v. Commissioner

CHASE, Circuit Judge.

Edwin D. Levinson filed an individual income tax return for 1939 and with his wife filed a joint return for 1940. The Commissioner determined a deficiency for each year and was sustained by the Tax Court. This petition to review followed and as the questions raised are identical for each year they will be discussed as one deficiency and as though Mr. Levinson were the only petitioner. Both petitions were filed on the cash basis and payments received by Mr. Levinson in each year as the result of agreements relating to a New York Stock Exchange seat which he owned were…