Legal Opinion

Salvatore v. Commissioner

United States Tax Court

Decided February 4, 1970No. Docket No. 5150-67Unpublished

1Opinion of the Court

Susie Salvatore v. Commissioner.

Salvatore v. Commissioner

Docket No. 5150-67.

United States Tax Court

T.C. Memo 1970-30; 1970 Tax Ct. Memo LEXIS 331; 29 T.C.M. (CCH) 89; T.C.M. (RIA) 70030;

February 4, 1970. Filed

Richard S. Pastore, for the petitioner. Larry Kars and Jay S. Hamelburg, for the respondent.

FEATHERSTON

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge: Respondent determined a deficiency in petitioner's income tax for 1963 in the amount of $31,016.60. The only issue presented for decision is whether petitioner is taxable on all or only one-half of the gain realized on the sale…

2Cases cited5 opinions

  1. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  2. John E. Palmer v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1965
  3. Palmer v. CommissionerUnited States Tax Court · 1965
  4. Usher v. CommissionerUnited States Tax Court · 1965
  5. Deinert v. CommissionerUnited States Board of Tax Appeals · 1928

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