Livingston v. Commissioner

Guy Livingston v. Commissioner.

Livingston v. Commissioner

Docket No. 6326.

United States Tax Court

1945 Tax Ct. Memo LEXIS 65; 4 T.C.M. (CCH) 943; T.C.M. (RIA) 45314;

October 9, 1945

Milton S. Gould, Esq., for the petitioner. Thomas R. Charshee, Esq., for the respondent.

MURDOCK

Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency of $5,068.60 in the income tax of the petitioner for the calendar year 1941. The petitioner for the calendar year 1941. The petitioner, a nonresident alien, contends that he was not engaged in business in the United States during 1941 as an…