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CARTER v. COMMISSIONER

Docket Nos. 11523, 11524.

9 T.C. 364 (1947)

SUSAN J. CARTER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. OIL TRADING COMPANY, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 17, 1947.

Attorney(s) appearing for the Case

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

Sheldon V. Ekman, Esq., for the respondent.

These cases, duly consolidated, involve deficiencies as follows: For the year 1942, Docket No. 11524, Oil Trading Co., deficiency in income tax of $1,760.73 and in excess profits tax of $1,727.44; for the year 1943, Docket No. 11523, Susan J. Carter, deficiency in income tax of $11,271.45. The questions presented are whether amounts received in 1943 by Susan J. Carter (under contracts distributed to her in the liquidation of Oil Trading Co.) constitute ordinary income or...

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