The Commissioner determined a deficiency of $12,829.27 in petitioner's income tax for 1939, and petitioner assails the inclusion in its gross income of $66,668 as a constructive receipt.
FINDINGS OF FACT.
Petitioner, a Texas corporation now in liquidation filed its return for 1939 at Austin, Texas. Its accounts and returns were on the cash receipts and disbursements basis.
On December 23, 1937, Dee Davenport and his wife, Osceola H. Davenport, executed...
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