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WILLIAMS v. COMMISSIONER

Docket Nos. 4255, 4256.

5 T.C. 639 (1945)

CHARLES J. WILLIAMS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. GRACE McDONALD WILLIAMS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated August 27, 1945.

Attorney(s) appearing for the Case

John S. Breckinridge, Esq., for the petitioners.

E. E. Strickland, Esq., for the respondent.

These consolidated proceedings involve redeterminations of deficiencies in income tax for the taxable year 1941, in the following amounts: Docket No. 4255, $1,782.99, and Docket No. 4256, $2,038.44.

The issue before us is whether the sum of $20,000 received by the petitioners represents ordinary income or whether it constitutes a capital gain. If it is a capital gain, the respondent affirmatively asserts that the sum of $20...

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