STORMFELTZ-LOVELEY CO. TRUST v. COMMISSIONER

Memorandum Findings of Fact and Opinion

The Commissioner has determined deficiencies in petitioner's income tax for the years 1938 and 1939 as follows: $6,661.30 for 1938, and $2,451.09 for 1939. The deficiency for 1938 is due to three adjustments which the Commissioner has made in the return filed by petitioner for that year on form 1041, as follows:

  Unallowable Deductions and
  Additional Income:

    (a) Rental income .......    $ 9,298.27
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