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JOSEPHSON v. COMMISSIONER

Docket No. 9990.

6 T.C.M. 788 (1947)

Benjamin Josephson v. Commissioner.

United States Tax Court.

Entered June 25, 1947.

Attorney(s) appearing for the Case

Morris Shilensky, Esq., and Julian G. Culver, Esq., for the petitioner. Rigmor O. Carlsen, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency of $8,558.04 in the income tax of the petitioner for the calendar year 1941. The Commissioner, in determining the deficiency, held:

"In accordance with Section 19.22(a)-3 of Regulations 103 common stock of a value of $20,000 received in consideration of past services rendered is included in taxable income."

One issue for decision is whether he erred in that holding...

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