Atlas v. Commissioner

Edward A. Atlas v. Commissioner.

Atlas v. Commissioner

Docket No. 2319.

United States Tax Court

1945 Tax Ct. Memo LEXIS 318; 4 T.C.M. (CCH) 111; T.C.M. (RIA) 45044;

January 27, 1945

Edgar W. Pugh, Esq., 3353 Penobscot Bldg., Detroit, Mich., for the petitioner. Philip M. Clark, Esq., for the respondent.

SMITH

Memorandum Findings of Fact and Opinion

SMITH, Judge: This proceeding is for the redetermination of a deficiency of $31,424.53 in petitioner's income tax for 1940. The questions in issue are whether the petitioner realized taxable income in 1940 when he surrendered bonds which he had purchased at…