Harris W. Bradley and Patricia G. Bradley v. Commissioner of Internal Revenue

NORTHROP, District Judge.

In this appeal, the Bradleys, petitioners herein, seek a reversal of a decision of the Tax Court of the United States affirming a determination of the Commissioner of Internal Revenue of a deficiency assessment against them in the amount of $1,955.56 for the year 1958. The Commissioner treated as ordinary income a payment of $5,000 made by Harris W. Bradley’s employer as a guarantee on the loss incurred in the sale of the Bradley home in Wilmington, Delaware.

We affirm the Tax Court’s decision.

Harris W. Bradley was, prior to May 1, 1957, employed by the duPont company.…