Kazan v. Commissioner

Abraham E. Kazan and Freda Kazan v. Commissioner.

Kazan v. Commissioner

Docket No. 60371.

United States Tax Court

T.C. Memo 1957-44; 1957 Tax Ct. Memo LEXIS 209; 16 T.C.M. (CCH) 196; T.C.M. (RIA) 57044;

March 15, 1957

Phillip I. Blumberg, Esq., for the petitioners. William F. Chapman, Esq., for the respondent.

KERN

Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency in petitioners' income taxes for 1951 in the amount of $3,474.89.

The only issue for decision is whether a payment of $25,000 to petitioner Abraham E. Kazan in 1951 represented at least 80 per cent of the total…