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DURDEN v. COMMISSIONER

Docket Nos. 109749, 109750.

3 T.C. 1 (1944)

RAY DURDEN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ROBERT L. STEPHENS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated January 7, 1944.

Attorney(s) appearing for the Case

H. C. Holbrook. Esq., for the petitioners.

Charles P. Bagley, Esq., for the respondent.

These proceedings, duly consolidated, involve income taxes for the calendar year 1939. The Commissioner determined a deficiency of $56.74 against Ray Durden, and of $807.47 against Robert L. Stephens. The income tax returns of both petitioners were filed with the collector for the district of Georgia, at Atlanta, Georgia. Error is urged in the disallowance by the Commissioner of deductions claimed under section 23 (e)-3 of the Internal Revenue Code, that is, (1) whether the...

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