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JERGENS v. COMMISSIONER

Docket No. 111757.

2 T.C.M. 385 (1943)

Andrew Jergens v. Commissioner.

United States Tax Court.

Entered June 30, 1943.

Attorney(s) appearing for the Case

Carl M. Jacobs, Esq., 2301 Union Central Bldg., Cincinnati, O., and Murray M. Flack, Esq., 2301 Union Central Bldg., Cincinnati, O., for the petitioner. John O. Durkan, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The respondent determined a deficiency of $27,129.16 in the petitioner's income tax for the year 1939.

The issues now in controversy are:

(1) Whether or not the net income of the Amy Branch Jergens Trust constituted taxable income to the petitioner, under the provisions of section 22(a) of the Internal Revenue Code.

(2) Whether or not the petitioner is entitled to deduct from his gross income, as provided...

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